UBS AM (AMERICAS) LLC - CIG FORM ADV PART 2A

UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Form ADV Part 2A Brochure Item 1: Cover Page Credit Investments Group, a distinct business unit of UBS Asset Management (Americas) LLC 1285 Avenue of the Americas New York, NY 10019 (212) 713-2000 https://www.ubs.com/us/en/assetmanagement SEC File Number 801-34910 March 31, 2026 This brochure (“Brochure”) provides information about the qualifications and business practices of the Credit Investments Group (“CIG”), a distinct business unit of UBS Asset Management (Americas) LLC (“UBS AMA LLC”). The information in this brochure is solely information where UBS AMA LLC serves as the investment adviser for the CIG business. If you have any questions about the contents of this Brochure, please contact OL-CIG_ADV@ubs.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the "SEC ") or by any state securities authority. Additional information about UBS Asset Management (Americas) LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. UBS Asset Management (Americas) LLC’s CRD number is 106838. UBS Asset Management (Americas) LLC is registered as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. Page 1 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 2: Material Changes Credit Investments Group (“CIG”), a distinct business unit of UBS Asset Management (Americas) LLC ("UBS AMA LLC") filed its most recent annual update to Brochure on March 31, 2025, and its latest other-than-annual update on January 9, 2026 to reflect material changes to its principal office and place of business address. Sale of the O’Connor Business Unit Transaction Overview On May 28, 2025, UBS AMA LLC announced that it had entered into an agreement ( in its final form as amended through December 19, 2025) to sell its O’Connor business unit (“ O’Connor Sale”) to Cantor Fitzgerald, L.P. (“Cantor Fitzgerald”). Cantor Fitzgerald is a privately-owned Delaware limited partnership which provides a broad array of financial services worldwide, including through its asset management division. The O’Connor Sale comprised substantially all of O’Connor’s going-concern investment strategies consisting of registered and private funds as well as separately managed accounts (Global Multi - Strategy Alpha, Event Driven / Global Merger Arbitrage, Private Credit / Capital Solutions, and Commodities). The transaction closed in three stages, with the first closing occurring on December 31, 2025 (11:59 p.m. ET); the second one on February 1, 2026; and the third one on March 31, 2026. One O’Connor fund sub advised by UBS AMA LLC - the UBS (Lux) Commodity Index Plus USD Fund - is transferring to Cantor Fitzgerald on April 1, 2026 for local Luxembourg regulatory reasons. The related portfolio management and support teams, including investment specialists, technology, legal, compliance, and operations personnel, were transferred to Cantor Fitzgerald at the respective closing dates. The 1st closing of the O’Connor Sale included O’Connor’s Global Multi-Strategy Alpha and Event Driven / Global Merger Arbitrage strategies. The 2nd closing covered O’Connor’s Private Credit / Capital Solutions strategies. The 3rd closing primarily covered O’Connor’s Commodities strategies. Transition Service Arrangements The O’Connor Sale took the form of an asset transfer, coupled with a Sub -Advisory Agreement (“SAA”), a Transition Services Agreement (“TSA”) and a Reverse Transition Services Agreement (“RTSA”), effective immediately upon the 1st closing date. The TSA and the RTSA are in effect until the 1st anniversary of the 3rd closing date, subject to a 3-month extension option. The SAA terminated on March 31, 2026. The TSA and RTSA relate to the provision of non-regulated services (e.g., middle office) from UBS to Cantor Fitzgerald (TSA) and Cantor Fitzgerald to UBS (RTSA), respectively, supporting O’Connor business that was not transferring at the 1 st or 2nd Closing. The SAA covered the provision of regulated services (e.g., trade execution and portfolio management) from the 1 st closing date for certain portions of one strategy of O’Connor (the Event Driven Strategy) operated from the United Kingdom and trade execution in the United States and the United Kingdom. O’Connor Strategies Retained by UBS AM for Wind-down and Liquidation The following O’Connor strategies consisting of private and other commingled funds, and a separate managed account, were not part of the O’Connor Sale: the Working Capital Finance Strategy, the China Long/Short Equity Strategy, and a Swiss Commodities Fund (together, “Retained O’Connor Strategies”). Following the 1st closing date of the O’Connor Sale, these strategies have been in the process of being wound down and liquidated, which is currently Page 2 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A expected to be completed by the end of the 2 nd quarter of 2026, except that the wind-down of the Working Capital Finance Strategy funds is expected to depend on the duration of the Chapter 11 bankruptcy proceeding of First Brands Group, LLC, one of main portfolio investments of the Working Capital Strategy funds. None of the Retained O’Connor Strategies are accepting new investors or making new investments, and no investment advisory or other activity is occurring in any of them, except for activities required for an orderly wind-down and liquidation. For the duration of the wind-down period, the Retained O’Connor Strategies are being incorporated into UBS AM (defined below), effective immediately following the 1st closing of the O’Connor Sale. Other Changes QPAM Exemption As described in more detail in Item 4: Advisory Business – ERISA Clients of this Brochure, since May 5, 2025, UBS AMA LLC has operated under a 1-year grace period provided by the Department of Labor’s QPAM class exemption PTE 84-14 after it lost its individual Qualified Professional Asset Manager (“QPAM”) exemption under PTE 2025-03. This loss was the result of a disqualifying event occurring in a legacy wealth management entity of Credit Suisse for conduct unrelated to UBS and predating UBS’ acquisition of Credit Suisse. On February 26, 2026, the Department of Labor published a new draft individual exemption for comment, which, if granted, would be valid for 5 years and stipulate substantially identical conditions to those in PTE 2025-03. Accordingly, the organizational structure of UBS AMA LLC comprises the following businesses: (1) the institutional advisory and fund business unit (“UBS AM”); (2) the multi-manager hedge fund, private credit, private equity, real estate and infrastructure advisory business unit (“ UGA”); (3) the Credit Investments Group (“CIG”) business unit, a global non-investment grade credit manager; and (4) the direct investment infrastructure advisory business, which is managed as part of the (“Global Real Assets Americas” or “GRA Americas”) business unit. The direct real estate and direct farmland investment businesses of GRA Americas operate through two affiliated registered investment advisers, as described in Item 4 – Advisory Business of this Brochure. We may update this Brochure at any time and will either send you a copy or offer to send you a copy (either electronically or in hard copy) as may be necessary or required, but at least on an annual basis. Clients and prospective clients should review this entire Brochure carefully. Additional information about CIG, including a copy of this and Brochures for other business units within UBS AMA LLC, is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 3 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................... 1 Item 2: Material Changes ...................................................................................................................... 2 Privacy Notice ....................................................................................................................................... 5 Item 4: Advisory Business ...................................................................................................................... 8 Item 5: Fees and Compensation .......................................................................................................... 12 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................... 16 Item 7: Types of Clients....................................................................................................................... 18 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 20 Item 9: Disciplinary Information ........................................................................................................... 36 Item 10: Other Financial Industry Activities and Affiliations ................................................................... 38 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 46 Item 12: Brokerage Practices ............................................................................................................... 51 Item 13: Review of Accounts ............................................................................................................... 54 Item 14: Client Referrals and Other Compensation............................................................................... 55 Item 15: Custody ................................................................................................................................ 56 Item 16: Investment Discretion ............................................................................................................ 57 Item 17: Voting Client Securities.......................................................................................................... 58 Item 18: Financial Information ............................................................................................................. 59 Page 4 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Privacy Notice FACTS WHAT DO THE UBS ASSET MANAGEMENT US LEGAL ENTITIES (UBS AM US) DO WITH YOUR PERSONAL INFORMATION? Why? Financial companies choose how they share your personal inf ormation. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal inf ormation. Please read this notice caref ully to understand what we do. What? The types of personal inf ormation we collect and share depend on the product or service you have with us. For example, certain products or services may share less data than others, but in no case will we share more than what is stated in the table below. This inf ormation can include: ▪ Social Security number and contact inf ormation ▪ account balances, assets and account transactions ▪ investment programs, experience and risk tolerance How? All f inancial companies need to share customers’ personal inf ormation to run as part of their everyday business activities. In the section below, we list the reasons f inancial companies can share their customers’ personal inf ormation, the reasons UBS AM US chooses to share, and whether you can limit this sharing. Reasons we can share your personal information Does UBS AM US share? Can you limit this sharing? Yes No For our everyday business purposes– such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No For our marketing purposes–internally and/or to service providers to of f er our products and services to you and target our advertising Yes No For joint marketing with other financial companies Yes No For our affiliates’ everyday business purposes inf ormation about your transactions and experiences Yes Yes For our affiliates’ everyday business purposes inf ormation about your creditworthiness Yes Yes For our affiliates to market to you For nonaffiliates to market to you No We don’t share Page 5 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A To opt out, please notif y your primary UBS contact To limit our sharing For questions, please notif y your primary UBS contact Questions? What we do How does UBS AM US protect my personal information? To protect your personal inf ormation f rom unauthorized access and use, we use security measures that comply with f ederal law. These measures include computer saf eguards and secured f iles and buildings. How does UBS AM US collect my personal information? We collect your personal inf ormation, f or example, when you: ▪ open an account, or other investment programs ▪ give us your income inf ormation or provide account inf ormation ▪ give us your contact inf ormation We also collect your personal inf ormation f rom others, such as credit bureaus, af f iliates or other companies. Why can’t I limit all sharing? Federal law gives you the right to limit only: ▪ sharing f or af f iliates’ everyday business purposes— inf ormation about your creditworthiness ▪ af f iliates f rom using your inf ormation to market to you ▪ sharing f or nonaf f iliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below f or more on your rights under state law. Definitions Affiliates Companies related by common ownership or control. They can be f inancial and nonf inancial companies. ▪ Our affiliates generally include companies with a UBS name and partnerships and other investment vehicles such as those listed in the UBS AM US legal entities section below. Nonaffiliates Companies not related by common ownership or control. They can be f inancial and nonf inancial companies. ▪ UBS AM US does not share with nonaffiliates so they can market to you and information with non-affiliates is shared only for everyday business purposes. Joint marketing A f ormal agreement between nonaf f iliated f inancial companies that together market f inancial products or services to you. ▪ Our joint marketing partners include categories of companies, such as broker-dealers and placement agents. Page 6 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Other important information State Law: We follow state law if it provides you with additional privacy protections, including: California residents - If you do not want us to share your information with our affiliates regarding your creditworthiness or to market their products and service s to you, please let us know by using the options provided in the “To limit our sharing” section on page 1; Vermont residents - we automatically treat customers with a Vermont mailing address as having limited our sharing with affiliates unless you give us authorization for such sharing using the options provided in the “To limit our sharing” section on page 1. North Dakota residents - We will not disclose information we collect about you to non-affiliated third parties to market to you, other than as permitted by North Dakota law, unless you authorize us to make those disclosures by using the options provided in the “To limit our sharin g” section on page 1. Nevada residents - We are providing you this notice under state law. You may be placed on our internal Do Not Call List by following the directions in the “To limit our sharing” section on page 1. Nevada law requires we provide the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Avenue, Suite 3900, Las Vegas, NV 89101; Phone number: 702- 486-3132; email: AgInfo@ag.nv.gov. UBS AM US legal entities Registered Investment Advisors: UBS Asset Management (Americas) LLC; UBS Realty Investors LLC; UBS Farmland Investors LLC Broker Dealers: UBS Asset Management (US) Inc.; UBS Fund Services (USA) LLC Trust Company: UBS Asset Management Trust Company Registered Funds: collectively, UBS AM Family of Funds, the PACE Funds, the CS Funds, and all closed-end funds managed by UBS AM US Page 7 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 4: Advisory Business Overview This section of the Brochure contains a general description of UBS Asset Management (Americas) LLC (“UBS AMA LLC”) and its organizational and ownership structure, and specific information related to the Credit Investments Group (also referred to as “we,” “our,” or “CIG”), a distinct business unit of UBS AMA LLC, including the types of advisory services we provide and the investment instruments we use, how we tailor advisory services to client needs, and, if applicable, our participation in managed account programs (wrap fee programs). General description and ownership UBS AMA LLC is an investment adviser registered with the SEC and an indirect, wholly owned subsidiary of UBS Group AG ("UBS"), a publicly traded company (NYSE: UBS). As of the date of this Brochure, UBS Americas Inc. directly owns 75.3%, CSAM Americas Holding LLC directly owns 22.7%, and UBS AM Holdings LLC directly owns 2.0% of the outstanding membership interests of UBS AMA LLC. UBS Americas Holding LLC owns 100% of UBS Americas Inc. UBS AG owns 100% of the outstanding equity of UBS Americas Holding LLC, and ultimately UBS Group AG owns 100% of the outstanding equity of UBS AG. UBS AMA LLC is registered with the U.S. Securities and Exchange Commission ("SEC") as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the "Advisers Act"). The operational structure of UBS is composed of the Group Functions and four primary business divisions: Global Wealth Management, Personal & Corporate Banking, Asset Management, and the Investment Bank. The Asset Management business division was formed following the merger of Union Bank of Switzerland and Swiss Bank Corporation in 1998, thereby creating UBS. In 2000, UBS integrated the investment teams of its various asset management businesses: UBS Asset Management, Brinson Partners (a Chicago firm established in the 1980s) and Phillips & Drew (a London firm established in 1895). In 2002, with the integration complete, the division rebranded as UBS Global Asset Management and is known today as “UBS Asset Management”. UBS AMA LLC is part of the UBS Asset Management business division of UBS and was established in 1989. On March 1, 2024, UBS AMA LLC converted its legal form from a Delaware corporation to a limited Delaware liability company in anticipation of two internal legal entity transactions and integration with Credit Suisse. On April 1, 2024, UBS AMA LLC absorbed two of its wholly owned subsidiaries, UBS Hedge Fund Solutions, LLC and UBS O’Connor, LLC, and on May 1, 2024, Credit Suisse Asset Management, LLC (“CSAM”) was merged with and into UBS AMA LLC with UBS AMA LLC as the surviving entity in all three transactions (the latter referred to herein as the “CSAM Merger”). The O’Connor business unit of UBS AMA LLC was subsequently sold as described in more detail in Item 2: Material Changes – Sale of O’Connor Business Unit of this Brochure. UBS AMA LLC’s current organizational structure permits each of its distinct business units to operate independently within UBS AMA LLC, separated by information barriers. 1. UBS AM, formerly the primary business of UBS AMA LLC, is a business unit within UBS AMA LLC that offers Active Equities, Active Fixed Income, Active Multi-Asset, Portfolio Engineering & Trading ("PE&T") and Partnership Solutions investment strategies, as well as advisory services to funds registered under the Investment Company Act of 1940, as amended (the " Investment Company Act" or "1940 Act"). Additionally, UBS AM offers discretionary advisory services for model‑based investment strategies. As part of the CSAM Merger, certain legacy CSAM businesses that are in run-off or wind-down mode were incorporated into UBS AM. Page 8 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A 2. Unified Global Alternatives (“UGA”) offers a comprehensive spectrum of multi-manager alternatives investment solutions and advisory services, including a wide range of multi-manager strategies and co-investment opportunities which provide broad based, diversified exposure to hedge fund, private credit, private equity, real estate and infrastructure asset classes with various risk and return profiles. 3. Credit Investments Group ("Credit Investments Group" or "CIG") was added as a business unit within UBS AMA LLC following the CSAM Merger. CIG was established in 1997 and specializes in the management of portfolios of leveraged loans, high-yield bonds, illiquid credit instruments, and structured credit instruments, e.g., rated and unrated debt and equity tranches of collateralized loan obligations ("CLOs") in credit markets across a broad spectrum of products, including CLOs, separate managed accounts, registered investment companies and other commingled vehicles. Effective September 2025, CIG, through UBS AMA LLC and UBS Asset Management Credit Investments Group UK Ltd (“CIG UK”), engaged General Atlantic Service Company, L.P. and GASC APF, L.P. as sub-adviser to support CIG’s Private Credit Opportunities (“PCO”) fund complex. Additionally, effective March 2026, UBS AMA LLC acts as co-manager alongside CIG UK for designated CIG-advised European CLOs. 4. Global Real Assets Americas (“GRA Americas”) is comprised of the direct infrastructure business area within UBS AMA LLC, as well as through two separate SEC- registered investment advisers: UBS Realty Investors LLC ("RE-US"), which offers direct real estate investments through commingled real estate funds and individually managed discretionary and non -discretionary real estate accounts; and UBS Farmland Investors LLC ("Farmland"), which offers advice to clients in connection with the acquisition or sale and management of agricultural real estate. R E-US and Farmland are part of GRA Americas and of the Asset Management division of UBS but are covered in separate brochures. Effective February 2026, GRA Americas reports ultimately into Investments, an internal organizational unit of UBS AMA LLC comprising UBS AM and CIG, in addition to GRA Americas. This Brochure is intended to cover the CIG business unit and its operations. Certain business units listed above have separate respective Brochures, which may be provided upon request. CIG's General Advisory Services CIG offers discretionary and non-discretionary investment management services and specializes in the management of portfolios of leveraged loans, high-yield bonds, illiquid credit instruments, and structured credit instruments (e.g., rated and unrated debt and equity tranches of CLOs) for various types of clients through a variety of vehicles including, but not limited to, Undertakings for Collective Investment in Transferable Securities (“UCITS”), U.S. and non-U.S. private pooled investment vehicles that may be organized as domestic and offshore limited partnerships, limited liability companies or similar investment vehicles; structured investments vehicles (such as CLOs); special purpose vehicles; alternative investment vehicles; co-investment vehicles; and single investor funds (“Private Funds”), U.S. investment companies registered under the Investment Company Act (“Registered Funds”), non-US Exchange-Traded Funds (“ETFs”) and together with the Private Funds, Registered Funds, and UCITS, "Funds"), and separately managed accounts for various types of clients, including public and private pension plans, corporations, not for profits, insurance companies, high net worth individuals and other business entities (“Accounts”). These advisory clients are referred to broadly as “clients” in this brochure. Specific investment objectives, strategies, risks, fees and expenses are described in detail in each client’s investment advisory or management agreement, indentures, offering documents and/or other governing documents (each as applicable, and collectively, “Governing Documents”). Page 9 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A CIG also serves as a collateral manager for CLOs, a type of private fund, which invests primarily in U.S. and European loans and high yield bonds. CIG’s portfolio management teams typically use fundamental, company-specific credit analyses when formulating investment advice or managing client assets but may also include technical factors that may influence trading levels and pricing, such as new issue calendar volumes, research cover and track record of the lead underwriter or agent. CIG may use additional or alternative approaches as it deems necessary or appropriate. Additionally, UBS AMA LLC frequently seeks the advice and assistance of its non-U.S. affiliates within UBS Asset Management when providing investment supervisory services to its clients (in such capacity, “Participating Affiliates”). Please see Item 10 Other Financial Industry Activities and Affiliates for further information. UBS AMA LLC may, in its discretion, delegate all or a portion of its advisory or other functions (including placing trades on behalf of clients) to a Participating Affiliate. The employees of such Participating Affiliates may provide portfolio management, research, financial analysis, order placement, and other services to CIG’s clients. Such employees will be acting as associated persons of UBS AMA LLC and of CIG in providing such services under the direct supervision of CIG. CIG remains responsible for the advice and services provided and clients will not pay an additional investment advisory fee as a result of such advice and services rendered by those associated persons, absent disclosure and express client consent . UBS AMA LLC has a global services agreement in place with its Participating Affiliates that is structured in accordance with a series of SEC no- action relief letters mandating that Participating Affiliates remain subject to the regulatory supervision of both UBS AMA LLC and the SEC in certain respects. UBS AMA LLC may also act as a sub-adviser to Funds and Accounts managed by its Participating Affiliates which may invest in varying mixtures of leveraged loans, high yield bonds and CLO tranches and other investments as outlined in the applicable Governing Documents. UBS AMA LLC and its Participating Affiliates may currently or in the future sponsor or advise other investment vehicles or portfolios of a similar nature. Types of Instruments CIG primarily manages portfolios comprised of: • • • senior secured bank loans and leveraged finance assets, including new issue and secondary offerings of senior secured and unsecured loans, second-lien loans, high yield bonds, mezzanine loans, and privately originated secured first- and second-lien loans; other alternative investments, which currently consist primarily of CLO equity and debt securities and unrated CLO warehouse investments, but can also include investments in other structured credit products, non-structured products, and derivatives; and, securities or instruments not referenced provided such actions are in the best interests of the client and disclosed within the Governing Documents for the client. Investment Limitations As part of UBS, CIG sits within a global financial services firm and, consequently, may be precluded from acquiring or selling certain securities or investments on behalf of itself or its clients as a result of inside information, conflicts of interest or applicable laws or regulations. Ultimate ownership by a foreign bank subjects UBS AMA LLC, including CIG and other business units, to certain provisions of the Bank Holding Company Act (“BHCA”). The BHCA, in certain circumstances, limits the ability of CIG to invest in stock issued by other U.S. companies and other bank holding companies that are subject to the BHCA. CIG may invest in securities or investments issued by UBS within the limits and restrictions set forth by applicable law. In addition, UBS AMA LLC and UBS adhere to global policies that require compliance with relevant legal and regulatory requirements. An example of such a requirement would be sanctions, which are any measure or restriction (including those often referred to as embargoes) taken by one or more countries, their respective Page 10 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A government agencies or by an international organization, aimed at restricting dealings of any kind with or involving another country, specific persons, legal entities, organizations or goods. UBS AMA LLC and UBS may also deem certain additional countries or industries to be high risk and may restrict business activities with certain countries, governments, government-controlled entities, territories, or persons. In some cases, business activities are expressly prohibited, where other cases may require pre-approval from regional compliance personnel before any business activity can be undertaken. Assets under Management Client regulatory assets under management for CIG and for UBS AMA LLC, respectively, as of December 31, 2025, are as follows: US Dollar Amount CIG Discretionary: $51,730,523,216 CIG Non-Discretionary: $0 CIG Total: $51,730,523,216 UBS AMA LLC Discretionary $563,949,029,253 $24,270,588,868 UBS AMA LLC Non- Discretionary UBS AMA LLC Total: $588,219,618,121 Page 11 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 5: Fees and Compensation Overview This section of the Brochure contains information regarding how CIG is compensated for investment advisory services. Management and Other Fees CIG has a standard fee schedule, which is summarized below. When providing investment advisory services, CIG commonly receives (except in the case of CLOs as described below) a management fee from a client in an amount equal to a percentage of the net assets under management as determined at the end of each calendar quarter, and may receive an incentive or performance fee generally consisting of a percentage of the client's profit or cash distributions, if any, subject in certain cases to a loss carry forward provision or a preferred return hurdle. Management fees for certain clients may also be calculated as a percentage of invested or committed capital or gross assets. The management fees and performance-based fees charged are not inclusive of all the fees and expenses that a client may pay or that may be borne by a client, including fees and expenses described elsewhere in this Item 5 under “Other Fees and Expenses.” Details of management fees and performance-based fees payable to CIG by its clients are outlined in each client’s relevant Governing Documents. Typically, management fees and performance-based fees payable to CIG are separate, distinct, and in addition to other expenses that may be charged to clients and disclosed in their applicable Governing Documents. Please see Item 6: Performance-Based Fees and Compensation for more details with respect to the payment of performance-based fees and potential conflicts. When providing investment advisory services to Funds and Accounts, CIG may receive advisory fees from those Funds and Accounts, and in cases where CIG acts as a sub-adviser to a Fund or Account, CIG may receive advisory fees from the primary investment adviser to such Fund or Account. Conversely, a portion of the management fees received by CIG may, in the case of certain Funds or Accounts, be paid to those Funds' or Accounts’ sub-advisers. Under certain circumstances and where permissible by regulations, the investment of an investor’s assets in a Fund or Account may result in multiple layers of fees paid to CIG and by such Fund or Account. Any such layered fees would be disclosed in the particular Governing Document s associated with the investment. CIG may impose minimum fees or fee equivalents above or below those stated her ein for certain clients depending on a number of factors, including the type of client, type of mandate, changing market conditions, and pre-existing relationships. Such minimum fees may be increased or decreased, depending on the specific circumstances of an individual client. CIG’s current basic annual management fee schedule for Accounts is as follows: Leveraged Loans 0.50% on first $50 mil. of assets 0.45% on next $50 mil. of assets 0.40% on assets over $100 mil. High Yield Bonds 0.50% on first $50 mil. of assets 0.45% on next $50 mil. of assets 0.40% on assets over $100 mil. Page 12 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Multi-asset Credit 0.50% on first $50 mil. of assets 0.45% on next $50 mil. of assets 0.40% on assets over $100 mil. CLO Equity Strategy 1.50% on first $50 mil. of assets 1.25% on next $50 mil. of assets 1.00% on assets over $100 mil. With respect to investment advisory services provided to CLOs, CIG will typically receive a “base management fee” and a “subordinated management fee,” each as a percentage of the aggregate principal balance of assets held by the CLO (subject to certain haircuts and exclusions), pursuant to the Governing Documents, which are provided and/or made available to prospective investors. In addition, CIG typically is entitled to an “incentive management fee” after a certain internal rate of return has been achieved on the subordinated notes and typically consists of a percentage of residual proceeds that would otherwise be distributable to the subordinated noteholders. For certain CLOs, CIG may receive a structuring fee, an initial incentive management fee, or other fees in connection with the closing of the CLO transaction. For CLO warehouses, CIG will typically receive a management fee based on the aggregate principal balance of assets held in the CLO warehouse. Fee terms for the CLOs and CLO warehouses are set forth in the relevant Governing Documents provided to investors. Further, investments in CIG-managed CLOs and CLO warehouses by other Funds or Accounts managed by CIG may be subject to certain management fee offsets or reductions as set forth in the applicable entities Governing Documents. Notwithstanding this discussion of fees in this section and in Item 6: Performance-Based Fees and Compensation below, Governing Documents can provide for a fee structure pursuant to which CIG is compensated based on entirely different criteria, metrics, or circumstances than those described herein. Fees payable by Funds and Accounts advised by CIG are described in those Funds' or Accounts’ Governing Documents. Fee Negotiation Management and performance-based fees charged by CIG are negotiable and may differ based upon a number of factors, including without limitation, overall fee arrangements, account complexity, overall relationship with UBS, the CLO market (in the case of CLOs), account size, assets under management and/or the terms of similar products or strategies managed by CIG. As a result, one client may pay a higher fee than another for which CIG is providing substantially similar services. The actual fee rate paid by each client will be set forth in the Governing Documents. Fees paid by the client to CIG may be higher or lower than the cost of similar services offered through other financial firms. Fees for certain clients may be waived, reduced, or calculated differently with respect to certain investors, including CIG’s employees or affiliates, at CIG’s sole discretion and as permitted by the client’s Governing Documents and applicable law. CIG employees and the employees of its affiliates also are permitted to establish Accounts with CIG that may be subject to reduced management fees or may be permitted to invest in one or more Funds on a reduced or waived fee and/or expense basis. In addit ion, certain of CIG’s employees have access to additional funding to facilitate investing in Funds. CIG believes that incentives that promote employee investments in Funds offered to clients reflects an alignment of interests between CIG and its clients, but also acknowledges that such investment could create the potential for a conflict of interest. Accordingly, UBS AMA LLC has policies and procedures in place to address employee investments in Funds. Page 13 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Most Favored Nation Clauses CIG may enter into “most favored nation” clauses wherein CIG agrees that the fees charged to a client shall not be more than the most favorable rates CIG may offer to any other comparable client for similar services (i.e., a client for whom CIG manages a portfolio of similar size and type, under similar terms and conditions, and with similar commercial expectations). Exceptions to these clauses generally include, but are not limited to, performance or incentive fees, relationship discount arrangements, clients affiliated with CIG or UBS AMA LLC, or clients that were initial investors (founders) in a strategy. Other Fees and Expenses Clients are generally responsible for their own account expenses. Clients also will be responsible for expenses, which include commissions and/or sales loads, management fees, and distribution/servicing fees, to the extent a client’s assets are invested in Funds or Accounts, that have their own fee and expense structures. Subject to the requirements of applicable law, applicable Governing Documents and the consent of each client, CIG is permitted to invest client assets in Funds or Accounts that it manages or those managed by our Participating Affiliates. CIG may use one or more custodians or prime brokers to provide custodial services in connection with the management of client assets. The cost of these services is not included in the management fees described above. Clients are responsible for the payment of any additional costs charged by the custodial service providers. The management fees charged by CIG also do not include the amount of any costs, expenses, or commissions that a broker or dealer will charge in connection with transactions executed on behalf of client accounts. In addition, a custodian or registered broker will impose certain costs or charges associated with servicing client accounts, such as margin interest, costs related to exchanging foreign currencies, odd lot differentials, regulatory fees, transfer taxes, exchange fees, wire transfer or postage fees, foreign clearing, settlement and custodial fees, and other fees or taxes required by law. For more information related to brokerage and other transactions costs, please see Item 12. Accounts with special investment guidelines or other special circumstances or requirements will be charged differently based on the services rendered. Some existing clients will pay different (higher or lower) fees that are not available to new or other existing clients. Assets or accounts of UBS AMA LLC’s Participating Affiliates also may be charged fees and expenses that are different from, and in most cases, lower than those charged to unaffiliated client accounts or assets. Accounts of the Participating Affiliates also may not be charged certain fees and expenses. Differences in fees and expenses can result in favoring some clients over others and will affect expectations as to future returns and risk. UBS AMA LLC will pay a portion of the advisory fee to any of its affiliates or entities or persons not affiliated with the UBS AMA LLC for certain clients referred to it by such entities or persons. Such fees are paid in accordance with applicable law. In addition, investors in Funds and Accounts will bear certain direct and indirect expenses associated with their investment. Expenses that are typically borne by these clients, and thus indirectly by investors in those Funds and Accounts, may include, without limitation: (i) expenses for administrators, valuation experts, accountants and other service providers; (ii) costs incurred in printing and distributing reports to investors; (iii) expenses for consulting services, including the review of marketing materials; (iv) all out-of-pocket expenses incurred in structuring, acquiring, holding and disposing of investments; (v) broken deal expenses; (vi) prime brokerage fees, bank service fees and other expenses incurred in connection with investments; (vii) fees and expenses related to borrowing; (viii) costs of litigation, directors & officers liability or other insurance and indemnification or extraordinary expense or liability relating to the affairs of the Fund; (ix) all out -of-pocket fees and expenses incurred in connection with compliance with U.S. federal, state, local, non -U.S. or other law or regulation; (x) expenses for regulatory reporting; (xi) fees and expenses related to the organization, operation or maintenance of intermediate entities used to facilitate the Fund’s or Account’s investment activities; (xii) expenses of winding up or liquidating the Fund or Account; (xiii) any taxes, fees or other governmental charges and Page 14 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A expenses incurred in connection with any tax audit, investigation, settlement or review of the Funds or Accounts; and (xiv) fees and expenses related to services rendered to a fund by a non-affiliated adviser or one of its affiliates. The applicable Governing Documents of each client sets forth the basis on which CIG’s fees may be reduced, and also provides a detailed description of the various expenses, in addition to the management and performance-based fees, that will be borne by that client, as well as potential conflicts of interest. Investors should review the Governing Documents carefully before making an investment. Payment of Fees Generally, fees may be paid in advance or arrears. The fees are then generally charged or billed on a quarterly basis and may be payable in advance or in arrears of the services rendered, depending on contractual agreement. In the event of termination, fees are normally charged on a pro rata basis through the date of termination, and any excess fees paid in advance are refunded. Generally, contract terminations can occur at the option of either CIG or the client and are generally effective upon receipt of 30- or 60-days written notice. CIG may agree with clients to make time weighted adjustments to quarterly fee calculations for asset flows representing an agreed percentage of the total assets under management during a quarter. Fees are negotiable and can vary from the schedules above to reflect circumstances that apply to a specific client or account. CIG may impose minimum fees or fee equivalents above or below those stated herein for client accounts depending on a number of factors, including the type of client, type of mandate, changing market conditions, and pre-existing relationships with CIG. Such minimum fees may be increased or decreased depending on the specific circumstances of an individual client. Fees payable by U.S. and foreign registered investment companies and Private Funds and Accounts advised by CIG, are described in greater detail in the products’ respective offering documentation. Under certain circumstances and where permissible by regulations, the investment of an investor’s assets in a Private Fund or Account may result in multiple layers of fees paid to CIG and such Private Fund or Account. Any such layered fees would be disclosed in the particular Governing Documents associated with the investment. Additional Compensation and Potential Conflicts of Interest Neither CIG nor its employees expect to receive a brokerage commission or any other compensation attributable to the sale of securities or investment products. However, CIG, its affiliates, its employees and clients, may receive other fees such as break-up or loan origination fees from companies in which Funds or Accounts may invest. Such fees may or may not be paid to, in whole or in part, the Funds or Accounts. CIG invests client assets in numerous borrowers and issuers and client portfolios may include loans and securities, including equity and/or debt securities obtained as a result of insolvency, debt restructuring or other proceedings and negotiations. Conflicts could arise when CIG makes investments in loans or senior securities, or securities with competing interests for different investment strategies. Page 15 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 6: Performance-Based Fees and Side-By-Side Management Overview This section of the Brochure contains information regarding performance-based fees and describes how we manage the conflicts of interest that may arise in managing client accounts. Performance-Based Fees In certain instances, CIG may be compensated under performance-based fee arrangements in accordance with the Advisers Act, including Rule 205-3 thereunder, applicable regulations and opinions of the Department of Labor under the Employee Retirement Income Security Act of 1974 (“ ERISA”) for employee benefit plan clients subject to ERISA, and any other applicable laws or regulations. As described in Item 5: Fees and Compensation, CIG may charge clients a negotiated performance fee based on a share of capital gains or capital appreciation of the assets under management, excess distributions remaining after payment of required amounts, for CLOs, a percentage of residual proceeds otherwise distributable to the subordinated noteholders upon achieving a certain internal rate of return, or based on some other measure, as agreed between CIG and its client. In some instances, the fee calculation will include a base or hurdle rate that must be exceeded before the fee is payable or, if losses have been incurred, a “high water mark” , which is a certain internal rate of return that must be achieved before the fee is payable, or a clawback of fees previously paid. Side-by-side Management Conflicts “Side-by-side management” refers to the concurrent management of multiple client accounts. As described above, CIG manages a variety of Funds and Accounts that pursue investment objectives and strategies that may be similar. Side-by-side management gives rise to a potential conflict when CIG’s interest may not be aligned with the best interest of one or more of its clients including the incentive to allocate opportunities to accounts that have been underperforming in an investment strategy; allocation of investment opportunities that favor performance fee-based accounts over advisory fee only accounts; allocation of investment opportunities that favor higher fee-paying clients; allocation of investment opportunities that favor accounts in which employees have a pecuniary interest; or a reluctance by CIG to mark down fair valued/illiquid investments in order to avoid: (i) a decline in performance; or (ii) an increase in performance volatility in a Fund or Account. Potential conflicts of interest may also arise with the allocation of limited investment opportunities to the extent that CIG has an incentive to allocate investments that are more likely to generate excess distributions, but that are also riskier or are expected to increase in value to certain accounts as allocated, including accounts with higher fee structures. In addition to having different fee structures, Funds or Accounts may hold inconsistent positions due to differences in investment objectives and strategies. At times, members of an investment management team may make an investment decision for one client that differs from an investment decision for another client or, alternatively, different teams within CIG may make different investment decisions for clients depending on the investment strategies they employ. At times, conflicts may exist when CIG and its affiliates invest, on behalf of our clients, in more than one part of the capital structure of the same issuer. UBS AMA LLC and CIG have policies and procedures designed to manage this potential conflict of interest. To address actual and potential conflicts of interest regarding performance-based fees, CIG has adopted policies and procedures regarding the aggregation and allocation of investments, which are designed to ensure that all clients are treated fairly and equitably over time and to prevent this form of conflict from influencing the allocation of investment opportunities among client accounts. CIG may allocate the same investment opportunity among different clients. Generally, CIG will make investment decisions for clie nt accounts in a manner that we determine is appropriate for each client in view of relative amounts of capital Page 16 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A available or new investments, each client’s investment guidelines and objectives, and the current portfolio of our clients at the time the investment decision is made. As a result and in certain situations, priority or weighted allocations may occur with respect to certain accounts, including but not limited to situations where clients have differing: (i) account restrictions, limitations and guidelines; (ii) cash available for investments; (iii) liquidity concerns; (iv) portfolio diversification targets or sector weightings; (v) tax or regulatory considerations; (vi) leverage limitations or volatility targets; (vii) ramp-up or ramp-down instances; or (viii) counterparty relationships. The Asset Management Risk Control team reviews Funds and Accounts for dispersion of investment performance and performance attribution analysis among similarly managed Funds and Accounts to assess variations in returns and meet periodically with CIG to discuss their analysis. Page 17 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 7: Types of Clients Overview In this section of the Brochure, we provide information about the types of clients to whom we provide investment advice. We also discuss the conditions we may impose on the management of client accounts. Fund or Account Clients CIG acts as the investment adviser or sub-adviser for various U.S. and non-U.S. public and Private Funds, Accounts and Registered Funds. Investments in Private Funds and Accounts may be intended only for certain financially sophisticated institutions, companies and individuals who can bear the risk of loss for some or all of their investment. For certain types of Private Funds and Accounts offered to U.S. investors, those investors must generally satisfy certain investor sophistication requirements, including that the client is an “accredited investor” (as defined in Rule 501(a) of Regulation D under the Securities Act of 1933, as amended; a “qualified purchaser” within the meaning of Section 2(a)(51) of the Investment Company Act; a “qualified institutional buyer” as defined in Rule 144A under the Securities Act of 1933, as amended; and/or a “qualified eligible person” under Rule 4.7 of the Commodity Exchange Act. For non-U.S. Private Funds, investors must be non-U.S. persons (as such term is defined in Regulation S promulgated under the Securities Act). Generally speaking, investors in Registered Funds are not subject to investor sophistication requirements, but such investors must still be prepared to bear the risk of loss for some or all of an investment. ERISA Clients CIG provides discretionary investment management services and non-discretionary investment advisory services to clients that are employee benefit plans covered by Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”). For ERISA plan clients, CIG is usually a “covered service provider” to the plan for purposes of ERISA Section 408(b)(2). CIG provides services to ERISA plans both as a registered investment adviser under the Advisers Act and as a fiduciary within the meaning of ERISA Section 3(21). When providing discretionary investment management services to ERISA plan s, it also serves as an investment manager as defined in ERISA Section 3(38). When providing services to ERISA plan clients, CIG intends to avail itself of available prohibited transaction exemptions, primarily Prohibited Transaction Exemption (“ PTE”) 84-14 (the “QPAM Exemption”). To the extent UBS AMA LLC relies on the QPAM Exemption, it must also comply with the UBS individual Prohibited Transaction Exemption 2025-03 (“PTE 2025-03”), issued by the Department of Labor, which, among other conditions, requires UBS AMA LLC to maintain, implement and follow written policies and procedures related to its ERISA client accounts. ERISA plan clients have a right to obtain a copy of the written procedures developed in connection with the individual PTE. - On May 5, 2025, Credit Suisse Services AG, a legacy Credit Suisse wealth management entity unrelated to the asset management business of UBS, pled guilty in connection with a conviction (“Conviction”) and a parallel non-prosecution agreement (“NPA”) with the U.S. Department of Justice to settle a long-running criminal investigation into Credit Suisse Group’s failure to implement a prior plea agreement from 2014 with respect to its legacy Switzerland - booked, cross-border wealth management business with U.S. taxpayers (the Conviction and the NPA together, the “CS Tax Resolution”). UBS was not involved in the underlying conduct, which predated its acquisition of Credit Suisse Group. The CS Tax Resolution would have constituted disqualifying events under PTE 2025-03, which would have prevented UBS AMA LLC and certain other Affiliated QPAMs (as defined in PTE 2025-03) from managing ERISA retirement plan assets (“ERISA Plans”). However, Section I(i) of the QPAM Exemption PTE 84-14 grants a 1-year transition period (the “Transition Period”), during which UBS AMA LLC can continue to operate as a QPAM for existing (but not new) ERISA Plan clients Page 18 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A under certain conditions. During the Transition Period, UBS AMA LLC may use PTE 84 -14 for ERISA Plan clients that had a pre-existing Written Management Agreement with UBS AMA LLC as of May 5, 2025. The Transition Period will last until the earlier of (a) May 5, 2026, or (b) the effective date of a new individual exemption, which, as of the date of this Brochure, was published by the Department of Labor for comment in draft form (February 26, 2026). The draft exemption, if granted, would be valid for 5 years and stipulates substantially identical conditions with those under PTE 2025-03. During the Transition Period, UBS will adhere to the conditions referenced in Section I(i) of PTCE 84-14 as well as the terms of its prior individual exemption, PTE 2025-03, despite that individual exemption technically no longer being in effect as a result of the CS Tax Resolution. UBS AMA LLC may also rely on exemptions other than the QPAM exemption. For example, it may rely on Prohibited Transaction Class Exemption 91-38 (“PTE 91-38”), which exempts prohibited transactions between a bank collective investment trust and certain parties in interest. At times, and to the extent other exemptions are not available (including the QPAM exemption and PTE 91 -38), it also may rely on statutory exemptions under Sections 408(b)(2) or 408(b)(17) of ERISA for transactions involving “service providers.” Other exemptions to ensure ERISA plan clients do not engage in transactions prohibited by ERISA may be available to, and relied upon by, UBS AMA LLC. Conditions for Managing Accounts All clients are required to enter into a written investment advisory agreement prior to the establishment of an advisory relationship. In addition, UBS AMA LLC conducts anti-money laundering/know your customer (“AML/KYC”) due diligence on clients in accordance with UBS Asset Management AML/KYC procedures. This process requires the collection of information from clients, including, without limitation, legal entity formation documents, officers' lists, tax forms and sources of wealth and funds. As described in Item 5 Fees and Compensation, CIG will generally impose minimum account sizes (or fee equivalents) for client accounts, depending upon a number of factors including the type of client, type of mandate, and/or pre-existing relationship with CIG or UBS. Such minimum account sizes may be increased or decreased depending upon the specific circumstances of an individual client. If the value of an account is less than the required minimum as a result of a client’s withdrawal of assets from the account, CIG may elect to terminate the relationship with the client. Exceptions are made at CIG’s sole discretion. Although we may advise a Fund or Account and place no limits on the size of that account, those who want to invest in the Fund or Account will generally be required to invest a minimum amount which varies depending on the Fund or Account. These requirements are disclosed in each respective entities’ Governing Documents. Exceptions are made at CIG’s sole discretion. Legal Proceedings CIG does not generally advise or act for clients as a legal advisor with respect to legal proceedings, including class actions, bankruptcies or other similar legal matters with respect to investments held or that were held in a client account CIG encourages clients to contact their custodians to ensure they are receiving the proper notification of any such legal proceedings. Further, CIG encourages clients to seek the advice of counsel regarding the participation and filing requirements associated with such matters. Unless otherwise expressly indicated, CIG will not be responsible for any failure to meet the filing or other requirements of legal proceedings with respect to securities held or that were held in a client account. Tax Matters Neither CIG nor UBS AMA LLC advise or act for clients on tax matters. CIG encourages clients to seek independent professional advice on any taxation matters. CIG will not be responsible for any failure to meet the filing or other requirements of tax proceedings with respect to securities held or that were he ld in a client account. Page 19 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Overview This section of the Brochure describes the methods of analysis we use to formulate investment advice and manage assets. We also discuss the material risks that clients should generally consider when investing with CIG. Methods of Analysis and Investment Strategies While our methods of analysis and investment strategies may vary to some extent across clients, in general, CIG focuses on investments in the global credit and fixed income markets and we are able to invest anywhere in the capital structure, including securities, loans and structured products. CIG may also employ a variety of additional investment strategies, including but not limited to investments in and arbitrage of futures, swaps and options; investments in various derivative instruments for hedging pur poses or to create exposure in lieu of holding actual securities or other instruments; or investments in currencies, including through forward contracts and investments in preferred equity, mezzanine debt and common equity. Credit selection is based on a bottom-up approach using fundamental research, capital structure and situational expertise, and we also may employ proprietary modeling techniques as well as quantitative and qualitative analysis. Overall, our investment approach generally draws upon several disciplines and strengths, including, but not limited to: fundamental, bottom-up credit analysis; credit trading and execution capabilities; customization of tailored credit solutions; and securitization and structuring expertise • • • • For corporate credit investments generally, the investment process involves an in-depth screening and assessment process for each potential investment under consideration. CIG conducts a fundamental analysis of the name and a financial analysis to evaluate the credit risks of an issuer. CIG derives the information used to make investment decisions on behalf of its clients from both internal and external resources. We may periodically seek the advice of economists and other investment professionals and consu ltants, internal and external, with respect to such matters as political conditions, proposed tax law changes, fiscal policy, general conditions of the economy, interest rates, actions of central banks and international affairs, among others. CIG will also consider relevant documentation, including credit agreements for each potential investment, to ensure they are structured and documented in accordance with applicable restrictions and requirements. For certain investment strategies, environmental, social and governance (“ESG”) factors are considered in the research process, which, alongside other qualitative considerations and financial metrics, may provide a more complete view of the risk/return characteristics of a potential investment. CIG may seek to incorporate ESG risk factors, in addition to other factors, into the research process to further assess medium- and longer-term risks of an issuer, including but not limited to potential reputational risk characteristics of a transaction. As CIG’s portfolio management teams use a variety of methods to identify, analyze and assess potential and existing investment opportunities, existing and potential investors should review the more detailed descriptions of those methods that are included in the relevant Governing Documents. Page 20 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Material Risks Investments in a Fund or Account managed by CIG involve a significant degree of risk. Neither CIG nor UBS AMA LLC can guarantee that it or any client will achieve investment objectives. A prospective client or investor in a Fund or Account should only invest with CIG if such investor is able to withstand a total loss of its investment and who have limited need for liquidity. Prospective investors should not construe the performance of any Fund or Account managed by CIG as providing any assurances regarding future performance. An investment in a Fund or Account managed by CIG is not a deposit in a bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Losses in Funds and Accounts will be borne solely by investors and not by CIG, UBS AMA LLC, or its affiliates (other than in its capacity as an investor or beneficiary of a restricted profit interest). Additionally, risks associated with the financial markets, investments in non-investment grade or distressed companies, the use of swaps, futures, options, hedging and short sale trading strategies, counterparty or prime broker risk, and investments in non-U.S. instruments, among others, may impact client investments. Although strategies employed by CIG do not generally involve frequent trading of securities or other investments, from time to time certain market conditions may result in frequent trading that may affect investment performance through increased brokerage and transactions costs and taxes. In addition to the risks above, the below risks are relevant to clients and investors contemplating an investment in a Fund or Account managed by CIG. This list of risk factors below is not a complete enumeration or explanation of the risks involved in a strategy, as the particular risks applicable to a client account will depend on the nature of the account, its investment strategy or strategies, and the ty pes of securities or instruments held. While CIG seeks to manage accounts in a manner where risks are appropriate to the strategy or objective, it is often not possible or desirable to fully mitigate risks. Prospective clients and investors should read this Brochure, along with any prospectus, offering memoranda, and any other Governing Documents before making an investment for specific information on investment strategies employed and risks applicable to their investment. Clients should also consult with their own legal, financial, and tax advisors before deciding whether to make an investment. General Risks Management Risk The investment strategies, techniques, and risk analyses employed by CIG may not produce their desired results. CIG may be incorrect in its assessment of the value of securities or instruments, or its assessment of markets or interest rate trends, which can result in losses to investments. Also, in some cases, derivatives or other investments may be unavailable, or CIG may choose not to use them under market conditions where their use, in hindsight, may be determined to have been beneficial. Personnel Risk CIG generally utilizes a team approach to managing investment portfolios. However, certain strategies may be dependent upon the expertise of certain key personnel, and any future unavailability of their services could have an adverse impact on the performance of clients invested in such strategies. Portfolio Liquidity Risk Unless otherwise agreed upon by a client and CIG, we will not be responsible for the client’s overall asset allocation or liquidity needs. In addition, certain of our strategies may be non -diversified, hold illiquid assets, and/or hold a low number of investments. There is a risk that investments cannot be readily sold at the desired time or price, and CIG may have to accept a lower price or may not be able to sell the investment at all. An inability to sell an investment can adversely affect the value of investments or prevent CIG from taking advantage of other investment opportunities. Liquid portfolio investments may become illiquid or less liquid after purchase due to low trading volume, adverse investor perceptions, and/or other market developments. In recent years, the number and capacity of dealers that make markets in fixed income securities has decreased. Consequently, the decline in dealers engaging in market making trading activities may increase Page 21 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A liquidity risk, which can be more pronounced in periods of market turmoil. Liquidity risk may be magnified in a rising interest rate environment or when investor redemptions from the Funds and Accounts may be higher than normal, causing increased supply in the market due to selling activity. Liquidity risk includes the risk that a client may experience significant net redemptions at a time when it cannot find willing buyers for its portfolio investments and can only sell its portfolio securities/investments at a material loss. Market Conditions and Volatility Market and economic conditions have, from time to time, caused significant disruption in the markets. The prices of a client’s investments, including, without limitation, common equity and related equity derivative instruments, high-yield securities, loans, convertible securities and derivatives, including fut ures and option prices, can be highly volatile. Price movements of forward, futures and other derivative contracts in which a client’s assets may be invested are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs, policies of governments and national and international political and economic events. In addition, governments from time to time intervene directly and by regulation, in certain markets, particularly those in government bonds, currencies, financial instruments, futures and options. Such intervention is often intended to directly influence prices and may, together with other factors, cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations. A client also is subject to the risk of the failure of any exchanges on which its positions trade or of their clearinghouses. These factors and general market conditions could have a material adverse impact on a client’s portfolio. Non-Diversification Risk A Fund or Account bears the risk that it may be more volatile than a diversified portfolio when it invests in assets in a smaller number of issuers. The gains and losses on a single security or investment may, therefore, have a greater impact on the portfolio. In addition, a strategy that invests in a relatively small number of issuers or of investments is therefore more susceptible to risks associated with a single economic, political, or regulatory occurrence than a more diversified strategy might be. Legal, Tax and Regulatory Risks Legal, tax, and regulatory developments may adversely affect an investment vehicle during the term of the investment. In addition, the securities and futures markets are subject to comprehensive statutes, regulations and margin requirements, other regulators and self-regulatory organizations and exchanges authorized to take extraordinary actions in the event of market emergencies. The regulation of derivatives transactions and funds that engage in such transactions is an evolving area of law and is subject to change b y government and judicial actions. The regulatory environment for private funds is subject to change. Legislative and regulatory changes in the U.S., Europe and other countries could affect an investment vehicle and its respective trading activities. Changes in the regulation of private funds and separately managed accounts and their trading activities may adversely affect the ability of an investment vehicle to pursue its investment strategy, its ability to obtain leverage and financing and the value of in vestments held by an investment vehicle. It is impossible to predict what, if any, changes in laws and regulations may occur, but any laws and regulations which restrict the ability of a Fund or Account to trade in securities or the ability of an investment vehicle to employ, or brokers and other counterparties to extend, credit in its trading (as well as other regulatory changes that result) could have a material adverse impact on an investment vehicles portfolio. Any such changes are expected to materially impact CIG and its affiliates, certain investment vehicles, and/or their investments, as well as increasing their expenses. Significant time and resources may be required to comply with new regulations, which potentially will detract from the time and resources dedicated to the investment vehicles. The investment vehicles and CIG will also be subject to regulation in jurisdictions in which they engage business. An investor should understand that an investment vehicle’s business is dynamic and is expected to change over time. Therefore, an investment vehicle may be subject to new or additional regulatory constraints in the future. The Governing Documents and any other documents received in connection with an investment in an investment vehicle cannot address or anticipate every possible current or futu re regulation that may affect an investment vehicle, CIG or their respective businesses. Such regulations may have a significant Page 22 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A impact on the operations of the investment vehicle, including, without limitation, restricting the types of investments the Fund or Account may make, preventing the Fund or Account from exercising its voting rights with regard to certain financial instruments and requiring the Fund or Account to disclose the identity of their investors. Volcker Rule Compliance UBS Group AG and its subsidiaries and affiliates, including UBS AMA LLC and CIG are subject to the prohibitions and restrictions of Section 13 of the Bank Holding Company Act, commonly known as the “Volcker Rule,” and the implementing regulations thereunder (the “Implementing Regulations”). The Volcker Rule generally prohibits “banking entities” from sponsoring and investing in “covered funds,” except as permitted pursuant to certain available exemptions. The term “covered fund” includes privately offered funds that rely on Sections 3(c)(1) or 3(c)(7) of the Investment Company Act to avoid being treated as "investment companies" under that Act. For non-U.S. banking entities like UBS Group, a non-U.S. organized fund that is offered and sold solely outside the United States may fall outside the definition of "covered fund." This category of funds oftentimes is referred to as "foreign excluded funds." In June 2020, U.S. federal financial regulators adopted revisions to certain covered fund provisions of the Implementing Regulations, which revisions become effective on October 1, 2020 ("Covered Fund Revisions"). The Covered Fund Revisions permit UBS to enter into certain previously prohibited covered transactions with a Fund, or any covered fund it controls, including certain transactions that are certain riskless principal transactions, and certain short-term extensions of credit, or asset purchases in exempt from the quantitative limits, collateral requirements, and low-quality asset prohibition under Section 23A of the U.S. Federal Reserve Act, the ordinary course of business in connection with payment, clearing and settlement activities. Further a Fund will be subject to the "market terms" requirements of Section 23B of the U.S. Federal Reserve Act. CIG will endeavor to minimize the impact of the Volcker Rule and the Implementing Regulations, but UBS’s interests in determining what actions to take in complying with the Volcker Rule may conflict with the interests of CIG or a particular client or counterparty, all of which may be adversely affected by such actions. In addition, further restrictions and limitations on UBS may emerge as additional regulatory guidance and interpretations are provided by the relevant regulatory agencies on the Volcker Rule and the Implementing Regulations and as the Implementing Regulations may be revised from time to time. To this end, and despite the issuance of the Implementing Regulations, certain aspects of the Volcker Rule remain unclear and susceptible to alternative interpretations. Portfolio Valuation Valuations of a client’s portfolio, which will affect the amount of CIG’s management fee and/or performance fee, involve uncertainties and discretionary determinations. Third-party pricing information may not be generally available regarding a significant portion of a client’s investments in certain asset classes, and in some circumstances, valuation models will be relied upon in order to value a client’s assets. CIG is not required and does not expect to receive independent third-party verification of these valuation models created by CIG. In addition, to the extent third-party pricing information is available, a disruption in the secondary markets for a client’s investments may limit the ability to obtain accurate market quotations for purposes of valuing those investments. Further, because of the overall size and concentrations in particular markets and maturities of positions that may be held by a client from time to time, the liquidation values of those securities and other investments may differ significantly from the interim valuations of those investments derived from the valuation methods described herein. Cybersecurity Risk As the use of technology has become more prevalent in the course of business, a strategy, Fund or Account, like other business organizations, has become more susceptible to operational, information security and related risks through breaches in cybersecurity. In general, cybersecurity failures or breaches of a strategy , Fund or Account or its service providers or the issuers of investments in which a strategy Fund or Account invests may result from deliberate attacks or unintentional events and may arise fr om external or internal Page 23 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A sources. Cybersecurity breaches may involve unauthorized access to a strategy or client account’s digital information systems (e.g., through "hacking" or malicious software coding) but may also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users). Cybersecurity failures or breaches affecting a strategy or a client’s investment advisor or any other service providers (including, but not limited to, accountants, custodians, transfer agents and financial intermediaries) have the ability to cause disruptions and impact business operations, potentially resulting in financia l losses, interference with a strategy, Fund or Account’s ability to calculate its net asset value, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensa tion costs, and/or additional compliance costs. In addition, substantial costs may be incurred in order to prevent any cybersecurity breaches in the future. While UBS AMA LLC has established business continuity plans in the event of, and risk management systems to prevent, such cybersecurity breaches, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Furthermore, CIG does not directly control the cybersecurity plans and systems put in place by a strategy, Fund or Account’s other service providers or any other third parties whose operations may affect a strategy, Fund or Account or its investors. The strategy, Fund, or Account, and its investors, could be negatively impacted as a result. Artificial Intelligence Risk The rapid development and increasingly widespread use of certain artificial intelligence technologies, including machine learning models and generative artificial intelligence (collectively "AI Technologies"), may adversely impact markets, the overall performance of the strategies or funds’ investments, or the services provided to the strategies or funds by their service providers. For example, issuers in which the strategies, or funds invest and/or service providers to the strategies or funds (including, without limitation, the strategies, or funds’ investment adviser, fund accountant, custodian, or transfer agent) may use and/or expand the use of AI Technologies in their business operations, and the challenges with properly managing its use could result in reputational harm, competitive harm, legal liability, and/or an adverse effect on business operations. AI Technologies are highly reliant on the collection and analysis of large amounts of data and complex algorithms, and it is possible that the information provided through use of AI Technologies could be insufficient, incomplete, inaccurate or biased leading to adverse effects for the strategies or funds, including, potentially, operational errors and investment losses. Additionally, the use of AI Technologies could impact the market as a whole, including by way of use by malicious actors for market manipulation, fraud and cyberattacks. AI Technologies (and the use of such technologies) may face regulatory scrutiny in the future, which could limit the development and use of this technology and impede the growth of companies that develop and use AI. Actual usage of AI Technologies by the strategies, funds’ service providers and issuers in which the strategies or funds invest will vary. AI Technologies and their current and potential future applications, and the regulatory frameworks within which they operate, continue to rapidly evolve, and it is impossible to predict the full extent of future applications or regulations and the associated risks to the strategies or funds. Referrals from Affiliates Employees of UBS AMA LLC's affiliates may receive payments from CIG or a client in the event the employee refers an opportunity that results in an investment by CIG on behalf of that client in a portfolio company or financial instrument. Any incentive payments are made consistent with client guidelines and UBS AMA LLC’s policies and procedures, which address related conflicts of interest. Identifying attractive investment opportunities at favorable prices is difficult and involves a high degree of uncertain ty. There can be no assurance as to the number of investment opportunities that will be made available to clients of CIG as a result of referrals. Page 24 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Non-Public Information In the ordinary course of business, CIG or its affiliates will come into possession of material non -public information with respect to an issuer of securities or other instruments (e.g., bank debt or investments involving a restructuring) in which a client has invested, or in which CIG intends to or is researching as a potential investment for its clients. Possessing such information may limit the ability of CIG to buy or sell such securities or other instruments on behalf of its clients. Accordingly, CIG m ay be prohibited from buying or selling such securities or other instruments on behalf of its clients at times when CIG might otherwise wish to buy or sell such investments. Investment Risks Risks of Fixed Income Investments Risk associated with investing in fixed income securities include: • Interest rate risk: The risk that changing interest rates may adversely affect the value of an investment. An increase in prevailing interest rates typically causes the value of fixed income investments to fall. Changes in interest rates will likely affect the value of longer-duration fixed income investments more than shorter-term investments and higher-quality investments more than lower-quality securities. When interest rates are falling, some fixed income investments provide that the issuer may repay them earlier than the maturity date, and if this occurs, the Fund or Account may have to invest these repayments at lower interest rates. A fixed income portfolio may face a heightened level of interest rate risk due to certain changes in monetary policy, such as certain types of interest rate changes by the Federal Reserve. Interest rate changes can be sudden and unpredictable and are influenced by a number of factors including government policy, inflation expectations and supply and demand. A substantial increase in interest rates may have an adverse impact on the liquidity of a security, especially those with longer maturities. Changes in government monetary policy, including changes in tax policy or changes in a central bank’s implementation of specific policy goals, may have a substantial impact on interest rates. There can be no guarantee that any particular government or central bank policy will be continued, discontinued or changed, nor that any such policy will have the desired effect on interest rates. The risks associated with rising interest rates have been pronounced as interest rates have risen from historically low rates. During periods when interest rates are low or there are negative interest rates, fixed income portfolio’s yield (and total return) also may be low, or the portfolio may be unable to maintain positive returns or minimize the volatility of the portfolio’s net asset value. • • • Credit risk: The issuer may default on its obligation to pay principal or interest, may have its credit rating downgraded by a rating organization, or may be perceived by the market to be less creditworthy. Lower-rated bonds or loans are more likely to be subject to an issuer’s default than investment grade (higher-rated) bonds or loans. Lower-rated bonds or loans may have less liquidity and be more difficult to value, particularly in declining markets. Prepayment risk: If interest rates decline, the issuer of an investment may exercise its right to prepay principal earlier than scheduled, forcing the account to reinvest in lower yielding investments. Extension risk: If interest rates rise, the average life of investments backed by debt obligations is extended because of slower than expected payments. This will lock in a below-market interest rate, increase the investment’s duration and reduce the value of the investment. • Counterparty risk: The risk that the counterparty to the transaction will default on its obligations under the relevant contract, including due to its financial failure or insolvency, and the related risks of having concentrated exposure to such a counterparty. • High yield risk: Investments in high yield securities and unrated securities of similar credit quality (commonly known as “junk bonds”) have historically been subject to greater levels of credit and liquidity risk than investment grade securities. High yield securities are considered predominately speculative with respect to the issuer’s continuing ability to make principal and interest payments. Page 25 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Loans Loan investments are subject to unique risks, including, without limitation: (i) the possible invalidation of an investment transaction as a fraudulent conveyance under relevant creditors’ rights laws; (ii) so - called lender- liability claims by the issuer of the obligations; (iii) environmental liabilities that may arise with respect to collateral securing the obligations; and (iv) limitations on the ability of a client to directly enforce its rights with respect to participations. In analyzing each bank loan or participation, CIG compares the relative significance of the risks against the expected benefits of the investment. Successful claims by third parties arising from these and other risks will be borne by the client. Investments in loan s due to extended settlement periods and loan participations may also subject a client to the risk of counterparty default. Clients holding a participation interest in a loan, may not have voting rights with respect to any waiver of enforcement of any restrictive covenant breached by a borrower. Holders of participation interests in loans are subject to additional risks not applicable to a holder of a direct interest in a loan. In the event of the insolvency of the selling institution, under the laws of the United States and the various States thereof, a holder of a participation interest in a loan may be treated as a general cr editor of the selling institution and may not have any exclusive or senior claim with respect to the selling institution’s interest in, or the collateral with respect to, the loan. Consequently, the holder of a participation interest in a loan will be subj ect to the credit risk of the selling institution as well as of the borrower. CIG is not required, and does not expect, to perform independent credit analyses of the selling institutions. Debt obligations in the form of loans are subject to additional liquidity risks. Loans are not generally traded in organized markets but are traded by banks, dealers, and other institutional investors engaged in syndications and loan participations, respectively. Consequently, there can be no assurance that there will be any market for any loan if the issuer is required to sell or otherwise dispose of such loan. Depend ing on the terms of the underlying loan documentation, consent of the borrower may be requ ired for an assignment, and a purported assignee may not have any direct right to enforce compliance by the issuer with the terms of the loan agreement in the absence of this consent. There can be no assurance that future levels of supply and demand in loan trading will provide an adequate degree of liquidity or that the current level of liquidity will continue. Because of the provision to holders of such loans of confidential information relating to the borrower, the unique and customized nature of the loan agreement, and the private syndication of the loan, loans are not as easily purchased or sold as a publicly traded security. Investments in Secured Loans Secured loans involve various degrees of risk of a loss of capital. The factors affecting an issuer’s secured leveraged loans, and its overall capital structure, are complex. Some secured loans may not necessarily have priority over all other debt of an issuer. For example, some secured loans may permit other secured obligations (such as overdrafts, swaps or other derivatives made available by members of the syndicate to the company ) or involve secured loans only on specified assets of an issuer. Issuers of secured loans may have two tranches of secured debt outstanding each with secured debt on separate collateral. Furthermore, the description of the liens referred to herein generally only applies to domestic assets and not non -U.S. assets. For the avoidance of doubt, non-U.S. assets may be included in the assets of a portfolio. In the event of Chapter 11 filing by an issuer, the Bankruptcy Reform Act of 1978, as amended authorizes the issuer to use a creditor’s collateral and to obtain additional credit by grant of a priority lien on its property, senior even to liens that were first in priority prior to the filing, as long as the issuer provides what the presiding bankruptcy judge considers to be “adequate protection” which may but need not always consist of the grant of replacement or additional liens or the making of cash payments to the affected secured creditor. The imposition of priority liens on a client's collateral would adversely affect the priority of the liens and claims held by the client and could adversely affect the client's recovery on the affected loans. Any secured debt is secured only to the extent of its lien and only to the extent of underlying assets or incremental proceeds on already secured assets. Moreover, underlying assets are subject to credit, liquidity, and interest rate risk. Page 26 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Investments in Unsecured Loans Unsecured loans are unsecured obligations of the applicable issuer, may be subordinated to other obligations of the issuer and generally have greater credit, insolvency and liquidity risk than is typically associated with investment grade obligations and secured obligations. Unsecured obligations will generally have lower rates of recovery than secured obligations following a default. Also, in the event of the insolvency of an issuer of any unsecured obligation, the holders of such unsecured obligation will be considered general, unsecured creditors of the issuer, will have fewer rights than secured creditors of the issuer and will be subordinated to the secured creditors with respect to the related collateral. Investments in Cov-Lite Loans A significant portion of the investments may be comprised of ”cov-lite” loans which contain limited, if any, financial covenants. Such loans either do not require the borrower to maintain debt service or other financial ratios and often do not contain restrictions on the ability of the borrower to incur additional debt, make certain restricted payments, change significantly its operations or to enter into other significant transactions that could affect its ability to repay such loans. Ownership of cov-lite loans may expose clients to different risks, including with respect to liquidity, price volatility, ability to restructure loans, credit risks and less protective loan documentation than is the case with loans that have incurrence and maintenance covenants. Distressed Investments Assets in client portfolios may become distressed investments (e.g., debt, equity, private claims and obligations of domestic and foreign entities experiencing significant financial difficulties, such as loan participations and assignments, trade claims and similar instruments), and clients may be exposed to significant risks. Among these risks are: (i) the difficulty in obtaining information as to the issuer’s true condition; (ii) regulatory risk, including laws related to fraudulent conveyances, voidable preferences, lender liability and bankruptcy; (iii) market risk; (iv) litigation risk; (v) liquidity risk; and (vi) at times, collection risk (especially with respect to sovereign debt). Moreover, to the extent a client invests in distressed sovereign debt obligations, it will be subject to additional risks and considerations not present in private distressed investments, including the uncertainties involved in enforcing and collecting debt obligations against sovereign nations, which may be affected by world events, changes in U.S. foreign policy and other factors outside of our control. Distressed investments may also be adversely affected by state and federal laws related to, among other things, fraudulent conveyances, voidable preferences, lender liability and a bankruptcy court’s discretionary power to disallow, subordinate or disenfranchise particular claims. In addition, distressed investments may be adversely affected by numerous uncertainties related to out -of-court restructurings and exchange offerings. Furthermore, the market prices of distressed investments are highly volatile, and spread between the bid and asked prices of such instruments are unusually wide. An interest in a non‑investment grade loan, bond or other debt obligation is generally considered speculative in nature and may default for a variety of reasons. Upon any investment defaulting, such investment may become subject to either substantial workout negotiations or restructuring, which may entail, among other things, a substantial reduction in the interest rate, a substantial write‑down of principal, and a substantial change in the terms, conditions and covenants with respect to such investment. The client may not own a large enough interest to control any such workout or restructuring activities or votes and, furthermore, the client may be unable to participate in certain restructurings due to limits on the client's activities and the types of assets the client can acquire. Such limitations, if they occur, may adversely affect the client and disadvantage the client compared to other lenders in the workout negotiations. Additionally, a workout or restructuring may be prevented from occurring if multiple lenders (which may include the client) have similar restrictions or limits on their activities or a workout or restructuring may be completed in a way which is disadvantageous to the obligation held by the client, for example, if the borrower enters into a more senior credit facility, resulting in the subordination of the client's obligation to super-senior lenders, or a recapitalization, restructuring or other transaction which the client is unable to participate in. In such circumstances, the ability of the client to recover in full on such obligation may be materially and adversely affected. Such negotiations or restructuring may be quite extensive and protracted over time and therefore Page 27 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A may result in substantial uncertainty with respect to the ultimate recovery on such investment. The liquidity for defaulted investments may be limited, and to the extent that such investments are sold, it is highly unlikely that the proceeds from such sale will be equal to the amount of unpaid principal and interest thereon.” Structured Securities CIG may invest client assets in strategies that consist of structured instruments, such as structured notes and warrants, and are offered and sold pursuant to a registration statement filed with the SEC or in a transaction exempt from registration under the U.S. Securities Act of 1933, as amended (the "Securities Act"). CIG may invest in structured investments issued by third-party issuers and may also invest directly in the referenced asset(s) or underlying exposure (i.e., the index) for a period of time in an effort to maintain the exposure intended by the strategies. The terms and risks of each structured investment vary materially depending on the creditworthiness of the issuer, the nature of the referenced asset, and the maturity of the instrument, among other factors. Investments in CDOs and CLOs CIG manages CLOs. In addition, certain Funds or Accounts managed by CIG may invest in CDOs or CLOs. These obligations present certain risks that are similar to those of the other types of fixed-income obligations in which clients may invest. Multiple tranches of securities are issued by the CDO or CLO, offering investors various maturity, yield and credit risk characteristics. Tranches are categorized as senior, mezzanine and subordinated/equity, according to their degree of credit risk. If there are defaults or the CDO's or CLO's collateral otherwise underperforms, scheduled payments to senior tranches take precedence over those of mezzanine tranches, and scheduled payments to mezzanine tranches take precedence over those of subordinated/equity tranches. In addition, the subordinated notes of a CDO or CLO generally do not benefit from any creditors’ rights or ability to exercise remedies under the indenture. The subordinated notes are not guaranteed by another party. Subordinated notes are subject to greater risk than the more senior, secured notes issued by the CDO or CLO. Investing in CDOs or CLOs also will entail a variety of risks, such as prepayment risk, credit risk, liquidity risk, market risk, structural risk, legal risk and interest rate risk. In addition, the performance will be affected by a variety of factors, including its priority in the capital structure of the issuer thereof, the availability of any credit enhancement, the level and timing of payments and recoveries on and the characteristics of the underlying loans or other assets that are being securitized, remoteness of those assets from the originator or transferor, the adequacy of and ability to realize upon any related collateral and the capability of the servicer or manager of the securitized assets. CDOs and CLOs often represent a leveraged investment an d may have significant volatility in value. The possibility of increased volatility and default rates in the structured finance sector may also adversely affect the price and liquidity of the CLOs included in the Fund ’s or Account’s investments. Issuers of CDO or CLO securities may acquire interests in loans and other debt obligations by way of sale, assignment or participation. The purchaser of an assignment typically becomes a lender under the credit agreement with respect to the loan or debt obligation; however, its rights can be more restricted than those of the assigning institution. In purchasing participations, an issuer of these securities will usually have a contractual relationship only with the selling institution and not the borrower. T he CDO/CLO generally will have neither the right to directly enforce compliance by the borrower with the terms of the loan agreement, nor any rights of set- off against the borrower, nor any rights to object to certain changes to the loan agreement agreed to by the selling institution. The CDO/CLO may not directly benefit from the collateral supporting the related loan and may be subject to any rights of set -off the borrower has against the selling institution. In addition, in the event of insolvency of the selling institution, under the laws of the states and the United States of America, the CDO or CLO may be subject to the credit risk of the selling institution as well as of the borrower. The underlying collateral of any CDO or CLO might not be diverse. For instance, the concentration of an underlying loan collateral portfolio in any one issuer would subject an investor in the CDO or CLO (especially if the client held the equity tranche of the CDO or CLO) to a greater degree of risk with respect to defaults by such issuer. Similarly, the concentration of a portfolio in any one industry would subject an investor in the Page 28 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A CDO or CLO (especially if the client held the equity tranche of the CLO) to a greater degree of risk with respect to economic downturns relating to such industry. Total Return Swaps Certain clients of CIG will obtain synthetic exposure to investment strategies through the use of one or more total return swaps. Total return swaps are contracts in which one party (i.e., the client) agrees to make periodic payments to another party (i.e., the counterparty, which may be an affiliate of CIG) based on the change in market value of the assets underlying the contract, which may include a specified security, basket of securities or securities indices during the specified period, in return for periodic payments based on a fixed or variable interest rate or the total return from other underlying assets. The total rate of return of the assets underlying the contract on which the swap is based may exhibit substantial volatility and in any given peri od may be positive or negative. The client’s investment in a total return swap is subject to leverage risk because, in addition to its total net assets, the client would be subject to investment exposure on the notional amount of the swap. In addition, there is the risk that the total return swap may be terminated by the client or the counterparty in accordance with its terms or as a result of regulatory changes. Foreign Investments Prices of a client's investments in foreign investments may go down because of unfavorable foreign government actions, political instability or the absence of accurate information about foreign issuers. In addition, political, diplomatic, or regional conflicts, terrorism or war, social and economic instability, and internal or external policies or economic sanctions limiting or restricting foreign investment, the movement of assets or other economic activity may affect the value and liquidity of foreign securities. The imposi tion of sanctions by governmental or supranational authorities on securities may hamper or prevent the trading of such investments and thus significantly lower their value. Also, a decline in the value of foreign currencies relative to the U.S. dollar will reduce the value of investments denominated in those currencies. In addition, foreign investments are sometimes less liquid and harder to sell and to value than investments of U.S. issuers. Each of these risks is more severe for investments of issuers in emerging market countries. Use of Derivatives Funds or Accounts managed by CIG may be permitted to invest in a variety of derivative instruments, including the purchasing and selling of credit default swap protection. The risks posed by derivatives include, but are not limited to: (i) credit risks (the exposure to the possibility of loss resulting from a counterparty’s failure to meet its financial obligations); (ii) market risks (adverse movements in the price of a financial asset or commodity); (iii) legal risks (an action by a court or by a regulatory or legislative body that could invalidate a financial contract); (iv) operational risks (inadequate controls, deficient procedures, human error, system failure or fraud); (v) documentation risks (exposure to losses resulting from inadequate documentation); (vi) liquidity risks (exposure to losses created by the inability to prematurely terminate a d erivative); (vii) system risks (the risk that financial difficulties in one institution or a major market disruption will cause uncontrollable financial harm to the financial system); (viii) concentration risks (exposure to losses from concentration of closely-related risks such as exposure to a particular industry or exposure linked to a particular entity); and (ix) settlement risks (the risk that a party to a contract faces when it has performed its obligations under a contract but has not yet received value from its counterparty). Government Securities Risk Yields available from U.S. Government and agency securities are generally lower than yields from many other fixed income investments. Further, there is a risk that the U.S. Government will not provide financial support to U.S. government agencies, instrumentalities or sponsored enterprises if it is not obligated to do so by law. Although many types of Government Securities, such as those issued by the Federal National Mortgage Association (“Fannie Mae”), Federal Home Loan Mortgage Corporation (“Freddie Mac”) and Federal Home Loan Banks may be chartered or sponsored by Acts of Congress, their securities are neither issued nor guaranteed by the U.S. Department of the Treasury and, therefore, are not backed by the full faith and credit of the United States. Page 29 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Use of Leverage For certain clients, CIG will employ leverage in a number of ways including purchasing instruments with the use of borrowed funds, selling securities short, trading options or futures contracts, using total return swaps, structured notes, asset-based lending facilities and repurchase agreements. The more leverage employed, the more likely it is that a substantial change will occur, either up or down, in the value of the instrument. Borrower Fraud Investing in loans or other debt instruments involves the possibility of material misrepresentation or omission on the part of the relevant borrower. CIG will generally rely upon the accuracy and completeness of representations made by borrowers to the extent reasonable when it makes investment recommendations but cannot guarantee such accuracy or completeness. Benchmark Rate Risk To the extent that a Fund or Account’s investments, borrowing facilities, hedging activities, or other assets or structures are tied to interest rates based on benchmark or reference rates, the Fund or Account may be subject to certain material risks, including the risk that a benchmark or reference rate is terminated, ceases to be published or otherwise ceases to be broadly used by the market. Regulators, central banks, governments, and other market participants have transitioned historical instruments to new benchmark rates. Such transitions have the potential to: increase volatility or illiquidity in markets; cause delays in or reductions to financing options for Funds and Accounts and issuers in which Funds and Accounts are invested; increase the cost of borrowing; reduce the value of certain instruments or the effectiveness of certain hedges; cause uncertainty under applicable legal documentation; or otherwise impose costs and administrative burdens relating to factors that include document amendments and changes in systems. Private placement risk Certain portfolios may hold securities that are neither listed on a stock exchange nor traded OTC, including privately placed securities and limited partnerships. As a result of the absence of a public trading market for these securities, they may be less liquid than publicly traded securities. Short sales risk Short sales involve the risk that the client will incur a loss by subsequently buying a security at a higher price than the price at which the client previously sold the security short. This would occur if the securities lender required the client to deliver the securities the client had borrowed at the commencement of the short sale and the client was unable to either purchase the security at a favorable price or to borrow the security from another securities lender. If this occurs at a time when other short sellers of the security also want to close out their positions, a "short squeeze" can occur. A short squeeze occurs when demand is greater than supply for the security sold short. Moreover, because the loss on a short sale arises from increases in the value of the security sold short, such loss is theoretically unlimited. By contrast, the loss on a long position arises from decreases in the value of the security and therefore is limited by the fact that a security's value cannot drop below zero. The risks associated with short sales increase when the client invests the proceeds received upon the initial sale of the security because the client can suffer losses on both the short position and the long position established with the short sale proceeds. It is possible that the client's securities held long will decline in value at the same time that the value of the securities sold short increases, thereby increasing the potential for loss. Cash/cash equivalents risk To the extent a Fund or Account holds cash or cash equivalents rather than securities or other instruments in which it primarily invests, it risks losing opportunities to participate in market appreciation and may experience potentially lower returns than its benchmark, if any or other portfolios that remain fully invested. Market Risk The market value of a client's investments may fluctuate, sometimes rapidly or unpredictably. Market risk may affect a single issuer, industry, or sector of the economy, or it may affect the market as a whole. In Page 30 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A addition, turbulence in financial markets and reduced liquidity may negatively affect investments. Global economies and financial markets are becoming increasingly interconnected, and conditions and events in one country, region or financial market may adversely impact issuers in a different country, region, or financial market. Events such as war, acts of terrorism, natural and environmental disasters, recessions, rapid inflation, cyberattacks or incidents, trade disputes and changes in trade regulation (including tariffs or other restrictions on trade), elevated levels of government debt, internal unrest and discord, the imposition of international sanctions, or pandemics or other public health threats could also significantly impact the markets. Policy changes by the U.S. government, central bank policy changes, and other economic or political changes within the United States and abroad may affect investor and consumer confidence and may adversely impact financial markets and the broader economy, perhaps suddenly and to a significant degree. Geopolitical tensions and armed conflicts can result in increased volatility, disrupt energy and supply markets, and negatively impact Funds and Accounts. These risks may be magnified if certain events or developments adversely interrupt the global supply chain and could affect companies worldwide. The scope and effect of these events are unpredictable but could have abrupt and significant impact s on financial markets and particular industries, sectors, and issuers. Volatility Risk CIG may invest in volatile instruments such as derivatives, which are frequently valued based on implied volatilities of such derivatives compared to the historical volatility of underlying financial instruments. Fluctuations or prolonged changes in the volatility of such financial instruments, therefore, can adversely affect the value of investments held by clients. In addition, many non -U.S. financial markets are not as developed or as efficient as those in the U.S., and as a result, price volatility may be higher for investments in non-U.S. financial markets. Systemic Risk Credit risk may arise through a default by one of several large institutions that are dependent on one another to meet their liquidity or operational needs, so that a default by one institution causes a series of defaults by the other institutions. This is sometimes referred to as a “systemic risk” and may adversely affect financial intermediaries, such as clearing agencies, clearing houses, banks, securities firms, and exchanges, with which CIG may interact on a daily basis. Systemic risk could result in increased volatility of financial markets and a greater risk of counterparty default. International Conflicts Wars and other international conflicts, such as the Israel-Palestinian conflict and the ongoing military conflict between Russia and the Ukraine has caused disruption to global financial systems, trade and transport, among other things. In response, multiple other countries have put in place sanctions and other severe restrictions or prohibitions on certain of the countries involved, as well as related individuals and businesses. However, the ultimate impact of these conflicts and their effect on global eco nomic and commercial activity and conditions, and on the operations, financial condition and performance of Funds, Accounts, or any particular industry, business or investee country and the duration and severity of those effects, is impossible to predict Financial Institution Risk; Distress Events An investment in a Fund or Account is subject to the risk that one of the Fund’s or Account’s banks, brokers, hedging counterparties, lenders or other custodians of some or all of the Fund’s or Accounts assets (each, a “Financial Institution”) fails to perform its obligations or experiences insolvency, closure, receivership or other financial distress or difficulty (each, a “Distress Event”). Distress Events can be caused by factors including eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance or accounting irregularities. In the event a Financial Institution experiences a Distress Event, CIG, the Funds, Accounts and/or their portfolio companies may not be able to access deposits, borrowing facilities or other services for an extended period of time or ever. Although assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation (“FDIC”), in the case of banks, or the Securities Investor Protection Page 31 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Corporation (“SIPC”), in the case of certain broker-dealers, amounts in excess of the relevant insurance are subject to risk of loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose increased risk of loss. Although in recent years governmental intervention has resulted in additional protections for depositors, there can be no assurance that governmental intervention will be successful or avoid the risk of loss, substantial delays or negative impact on banking or brokerag e conditions or markets. Any Distress Event has a potentially adverse effect on the ability of CIG to manage the Funds and Accounts and their investments, and on the ability of CIG, any Fund or Account and/or portfolio companies in which a Fund or Account invests to maintain operations, which in each case could result in significant losses and unconsummated investment acquisitions and dispositions. Such losses have the potential to include a Fund or Account to pay fees and expenses in the event the Fund or Account is not able to close a transaction (whether due to the inability to draw capital on a credit line provided by a Financial Institution experiencing a Distress Event, the inability of investors to make capital contributions or otherwise), as well the inability of a Fund or Account to acquire or dispose of investments at prices that the relevant managing entity believes reflect the fair value of such investments and/or the inability of portfolio companies to make payroll, fulfill obligations and maintain operations. Although CIG expects to exercise contractual remedies under the agreements with Financial Institutions in the event of a Distress Event, there can be no assurance that such remedies will be successful or avoid losses or delays. Many Financial Institutions require, as a condition to using their services or otherwise, that CIG and/or the relevant Fund or Account maintain all or a set amount or percentage of their respective accounts or assets with a qualified custodian, which heightens the risks associated with a Distress Event with respect to such custodians. Although CIG seeks to do business with custodians that it believes are creditworthy and capable of fulfilling their respective obligations to the Funds, CIG is under no obligation to use a minimum number of custodians with respect to any Fund, or to maintain account balances at or below the relevant insured amounts. Other Risks Possibility of different information rights Certain investors in a Fund may receive information regarding the Fund’s portfolio that is not generally available to other shareholders and, as a result, may be able to take actions (i.e., redeem their shares) on the basis of such information which, in the absence of such information, other shareholders do not take. In addition, the Fund’s swap counterparties may receive information regarding the Fund’s portfolio that is not generally available to other shareholders and, if such parties or their affiliates invest in the Fund, may be able to take actions (i.e., redeem their shares) on the basis of such information which, in the absence of such information, other shareholders do not take. Illiquidity Risk An investment in certain Funds or Accounts, including, but not limited to, Funds or Accounts with direct lending investment strategies, will require a long-term commitment, with no certainty of return. There most likely will be little or no near-term cash flow available to investors. In addition, the securities issued by Funds or Accounts typically cannot be sold by an investor except pursuant to a registration statement filed under the U.S. Securities Act of 1933, as amended (the “Securities Act”) or in a private placement or other transaction exempt from registration under the Securities Act and that complies with any applicable non -U.S. securities laws. Interests in such a Private Fund have not been registered under the Securities Act or any other applicable securities laws. In these cases, there is no public market for such interests and none is expected to develop. In addition, investors in such a Private Fund will generally be restricted from transferring their ownership interests in the Private Fund. Investors may be prohibited from withdrawing capital from certain Private Funds and, as such, will not be able to liquidate their investments prior to the end of the Private Fund’s term. Page 32 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Systems and Operational Risks Generally Clients depend on CIG to develop and implement appropriate systems for their activities. In particular, Funds and Accounts rely heavily and on a daily basis on financial, accounting and other data processing systems. In addition, Funds and Accounts rely on information systems to store sensitive information about the Fund or Account and its investors, as well as CIG and its affiliates. Certain of CIG’s activities with respect to its clients will be dependent upon systems operated by third parties, including brokers, prime brokers, administrators, market counterparties and other service providers, and CIG may not be in a position to verify the risks or reliability of such third party systems. Failure in such systems and similar clearance and settlement facilit ies or with other parties could result in mistakes made in the confirmation or settlement of transactions, or in transactions not being properly booked, evaluated or accounted for. Disruptions in CIG’s operations may cause a client to suffer, among other things, financial loss, the disruption of trading or investment operations, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing failures or disruptions could have a material adverse effect on a client. System Failure As CIG makes extensive use of computer hardware, systems and software, clients may be exposed to risks caused by failures of IT infrastructure and data. In addition, outright failure or a partial impairment (whether due to external situations or internal file corruption) of the underlying hardware, operating system, software or network may leave CIG unable to trade either generally or in certain of a client’s strategies, and this may expose the client to risk should the outage coincide with turbulent market conditions. To ameliorate this risk, backup and failover plans have been put in place by CIG. Nevertheless, in the worst case, CIG may have to liquidate a client’s entire portfolio as the only safe way to proceed should a crippling system outage occur. Data Feed Failure CIG utilizes data feeds from a number of sources. If these data feeds were to be corrupted, compromised, or discontinued in any manner, or not delivered or accessible in a timely manner, the models may not be properly formulated. This failure to receive the data feeds or receive the data feeds in a timely manner may leave CIG unable to trade on behalf of a client or may result in trades that are not aligned with CIG’s intended goal, and this may expose the client to risk of loss or loss of opportunities, in particular if the loss of the data feed coincides with turbulent market conditions. If the data feeds are compromised or discontinued in any material manner or if the data feeds are not delivered or accessible in a timely manner, it may result in a loss to the client, which could be material. Absence of Regulatory Oversight Although certain Private Funds or Accounts managed by CIG may be considered similar in some ways to an investment company, they are not required and do not intend to register as such under the Investment Company Act and, accordingly, investors in those vehicles are not accorded the protections of the Investment Company Act. FATCA The Foreign Account Tax Compliance Act (“FATCA”) requires all entities in a broadly defined class of foreign financial institutions (“FFIs”) to comply with a complicated and expansive reporting regime or be subject to a 30% U.S. withholding tax on (i) certain U.S. payments and (ii) gross proceeds from the sale of certain U.S. stocks and securities. Non-U.S. entities which are not FFIs also must either certify they have no substantial U.S. beneficial ownership or report certain information with respect to th eir substantial U.S. beneficial ownership or be subject to a 30% U.S. withholding tax on (i) certain U.S. payments and (ii) gross proceeds from the sale of certain U.S. stocks and securities). FATCA also contains complex provisions requiring participating FFIs to withhold on certain “foreign pass thru payments” made to non -participating FFIs and to holders that fail to provide the required information. The definition of a foreign pass thru payment” is still reserved under current regulations. However, the term generally refers to payments that are from non -U.S. sources but that are “attributable to” certain U.S. payments and gross proceeds described above. In general, these requirements apply to non-U.S. Funds, such as any non-U.S. UBS-sponsored Fund or Account advised by CIG. Among other things, FATCA compliance requires FFIs to obtain and review appropriate due diligence information with respect to certain existing and prospective investors. In addition, the reporting obligations Page 33 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A imposed under FATCA require FFIs to enter into agreements with the IRS to obtain and disclose information about certain investors to the IRS or, if subject to an Intergovernmental Agreement (“ IGA”), register with the IRS. IGAs are generally intended to result in the automatic exchange of tax information through reporting by an FFI to the government or tax authorities of the country in which such FFI is domiciled, followed by the automatic exchange of the reported information with the IRS. In the event FFIs are unable to comply with the preceding requirements, certain payments made to the FFIs may be subject to a 30% U.S. withholding tax, which would reduce the cash available to investors. These U.S. and foreign reporting requirements may apply to underlying entities and investors who are FFIs and the general partner (or similar managing fiduciary) has no control over whether such entities or investors comply with the reporting regime. Prospective investors in any Fund or Account should consult their own tax advisors regarding all aspects of FATCA as it affects their particular circumstances. Tax Treatment There may be changes in tax laws or interpretations of such tax laws adverse to a Private Fund (i.e., partnership) or its limited partners. There can be no assurance that the structure of a partnership or of any investment will be tax-efficient to any particular limited partner. Also, there can be no assurance that a partnership will have sufficient cash flow to permit it to make annual distributions in the amount necessary to permit Limited Partners to pay all tax liabilities resulting from their ownership of the partnership’s interests. Prospective investors are urged to consult their tax own advisers with reference to their specific tax situations. Environmental, Social and Governance (“ESG”) Matters CIG seeks to incorporate certain ESG factors into its investment process in certain investment strategies in accordance with its procedures and subject to its fiduciary duty and any applicable legal, regulatory or contractual requirements. There is no guarantee that CIG will be able to successfully implement its ESG practices while achieving its investment strategy. In addition, applying ESG factors to investment decisions is qualitative and subjective by nature, and there is no guarantee that the criteria utilized by CIG, or any judgment exercised by CIG, will reflect the beliefs or values of any particular investor. There are also significant differences in interpretations of what ESG characteristics mean by region, industry, and topic, as well as the interpretations of their scope and materiality. CIG’s interpretations and decisions are expected to differ from others’ views and could also evolve over time. In addition, in evaluating an investment, CIG expects to depend upon information and data provided by a number of sources, including the relevant investments and/or various reporting sources which could be incomplete, inaccurate or unavailable, and which could cause CIG to incorrectly assess a company’s ESG practices and/or related risks and opportunities. CIG does not intend independently to verify all ESG information reported by investments or third parties. Further, considering ESG qualities when evaluating an investment could result in the selection or exclusion of certain investments based on CIG’s view of certain ESG-related and other factors and could cause the relevant Funds or Accounts not to make an investment that they would have made or to make a management decision with respect to an investment differently than they would have made in the absence of the ESG practices. For avoidance of doubt, however, CIG does not expect to subordinate a Fund’s or Account’s investment returns or increase a Fund’s or Account’s investment risks as a result of (or in connection with) the consideration of any ESG factors. Further, ESG practices are evolving rapidly and there are different principles, frameworks, methodologies, and tracking tools being implemented by other asset managers, and CIG’s adoption and adherence to various such principles, frameworks, methodologies and tools is expected to vary over time. There is also a growing regulatory interest across jurisdictions in improving transparency regarding the definition, measurement, and disclosure of ESG factors. CIG’s ESG practices could become subject to additional regulation in the future, and CIG cannot guarantee that its current approach will meet future regulatory requirements or predict the manner in which any such future requirements (including any enforcement with respect thereto) could affect a Fund, Account or its investments, including with respect to future administrative burdens and costs. Management risk The risk that the investment strategies, techniques, and risk analyses employed by CIG may not produce the desired results. CIG’s judgments about the fundamental value of securities or investments or other factors that determine the attractiveness of investments acquired for a portfolio may prove to be incorrect. In addition, CIG's judgments about asset allocations, exposure to foreign currencies, credits, rates, and other Page 34 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A macro-economic factors may prove to be incorrect. In some cases, investments may be unavailable , or the firm may choose not to use them under market conditions when their use, in hindsight, may be determined to have been beneficial. In addition to the risks discussed above, clients may be subject to the following additional risks: (i) counterparty risk; (ii) foreign currency risks; (iii) commodities risk; and (iv) increased government regulation. Potential conflicts of interest also may arise from the relationship between CIG and any of its affiliates. Those conflicts are discussed in greater detail in Item 10 of this Brochure. For a complete discussion of an Account’s or a Fund’s strategies and the principal investments risks of those strategies, please read carefully the Governing Documents and any other documents received in connection with your investment . CIG's investment advisory activities, including client investments in Funds, Accounts or underlying portfolio company operations, are subject to various other risks and material adverse effects from events beyond the control of CIG, including terrorist attacks, cyberattacks, military conflicts, economic or political sanctions, pandemics, political unrest or natural disasters. To ameliorate these risks, business continuity plans have been put in place by UBS AMA LLC and its affiliates. Nevertheless, despite these efforts and plans, there can be no guarantee these events will not adversely affect CIG's advisory activities. Page 35 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 9: Disciplinary Information Overview In this section of the Brochure, we must disclose legal or disciplinary events material to a Client’s or prospective Client’s evaluation of our advisory business or the integrity of our management. United States District Court for the Eastern District of Virginia: Alexandria Division – CS Tax Resolution On May 5, 2025, Credit Suisse Services AG (“CSSAG”) pleaded guilty to one felony count of conspiracy to commit offenses against the United States, specifically, violations of Title 26, United States Code, Section 7206(2), the aiding, assisting, procuring, counseling and advising of the preparation and presentation of false income tax returns to the Internal Revenue Service of the Treasury Department, in violation of Title 18, United States Code, Section 371. CSSAG and its affiliates, UBS Group AG, UBS AG, and UBS Business Solutions AG, are now subject to several undertakings, including certain obligations during a three-year term of probation, and ongoing cooperation with the U.S. Department of Justice’s investigation. On May 9, 2025, CSSAG paid an aggregate monetary penalty of USD 371.9M in connection with the plea. CSSAG also contemporaneously entered into a separate non-prosecution agreement with the U.S. Department of Justice regarding U.S. taxpayers booked in the legacy Credit Suisse Singapore booking center. CSSAG is subject to several undertakings, including certain obligations during the three-year term of the non-prosecution agreement, and ongoing cooperation with the U.S. Department of Justice’s investigation. On May 9, 2025, CSSAG paid an aggregate monetary penalty of USD 138.7M in connection with the non-prosecution agreement. The CS Tax Resolution constituted a disqualifying event under Section 9(a) of the Investment Company Act, which prohibits an entity from serving as an investment adviser or principal underwriter for registered funds if the person or one of its affiliates is “permanently or temporarily enjoined by order, judgment, or decree of any court of competent jurisdiction . . . from engaging in or continuing any conduct or practice in connection with… the purchase or sale of any security.” On May 5, 2025, the SEC published a temporary order granting Section 9(a) relief to UBS AMA LLC and certain of its affiliates permitting it to continue to act for UBSAM’s SEC-registered funds in the various functions pending the issuance of a permanent order. On December 22, 2025, the SEC granted UBS AMA LLC and such affiliates permanent exemptive relief from Section 9(a) solely as a result of the CS Tax Resolution pursuant to the provisions of Section 9(c) of the Investment Company Act. Please refer to Item 4: Advisory Business – ERISA Clients in this Brochure for more information on the effect of this disciplinary event on UBS AMA LLC’s ERISA Plan clients. New Jersey Consent Judgment – Credit Suisse Asset Management On December 17, 2013, the Acting Attorney General of New Jersey on behalf of the Acting Chief of the New Jersey Bureau of Securities filed a complaint in the Superior Court of New Jersey, Mercer County Chancery Division, against Credit Suisse Securities (USA) LLC (“CSSU”) and certain of its affiliates in connection with US residential mortgage-backed securities (“RMBS”) trust certificates prior to the 2008 financial crisis. A consent order and final judgment (the “Consent Judgment”) was entered on October 24, 2022, that, in relevant part, ordered permanent relief under the New Jersey Uniform Securities Law (“ New Jersey Securities Law”) that CSSU and its affiliates not violate the New Jersey Securities Law. The Consent Judgment did not involve the Credit Suisse registered funds (for purposes of this disclosure section, the “CS Page 36 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Funds”) or the services that CSAM, Credit Suisse Asset Management Ltd. (“Credit Suisse UK” and together with CSAM, the “Credit Suisse Investment Advisers”), CSSU and their affiliates provided to the CS Funds. On November 14, 2022, certain Credit Suisse entities, including CSAM, voluntarily notified the staff of the SEC regarding the entry of the Consent Judgment. Following the entry of the Consent Judgment, the Credit Suisse Investment Advisers and CSSU continued to provide investment advisory and distribution services (the “Services”), as applicable, to the CS Funds based on their position at the time that the Consent Judgment did not trigger the disqualification provisions of Section 9(a). The Credit Suisse Investment Advisers, CSSU and certain of their affiliates nevertheless applied for an exemption from the disqualification provisions of Section 9(a) of the 1940 Act due to its broad scope. On June 7, 2023, the Credit Suisse Investment Advisers, CSSU and certain of their affiliates applied for and the SEC issued a temporary order, and on July 5, 2023, the SEC granted a permanent order, which provided: (i) a time-limited exemption from Section 9(a) to the Credit Suisse Investment Advisers, CSSU and certain of their affiliates, which enabled the Credit Suisse Investment Advisers and CSSU to provide the Services to the CS Funds until June 12, 2024 (by which point the Services were transitioned to UBS AMA LLC and its affiliate UBS Asset Management (US) Inc, and (ii) a permanent exemption from Section 9(a) to UBS Group AG and its affiliates. As agreed, UBS AMA LLC has merged with Credit Suisse Asset Management, LLC, with UBS AMA LLC as the surviving entity. UBS AMA LLC now acts as registered investment adviser to the CS Funds. On December 13, 2023, the SEC entered an administrative cease-and-desist order (the “Order”) against the Credit Suisse Investment Advisers and CSSU. The Credit Suisse Investment Advisers and CSSU consented to the Order without admitting or denying the findings therein. The SEC alleged in the Order that the Consent Judgment caused the Credit Suisse Investment Advisers and CSSU to be deemed ineligible to provide the Services to registered investment companies, including the CS Funds, under Section 9(a) of the 1940 Act and that, during the period from October 24, 2022 to June 7, 2023, the Credit Suisse Investment Advisers acted as investment adviser and CSSU acted as principal underwriter to the CS Funds in violation of Section 9(a) of the 1940 Act. Under the terms of the Order, the Credit Suisse Investment Advisers and CSSU were censured and agreed to cease and desist from committing or causing any violations and any future violations of Section 9(a) of the 1940 Act. The Credit Suisse Investment Advisers and CSSU agreed to pay disgorgement, prejudgment interest and civil penalties totaling $10,080,220. Other matters UBS AMA LLC has made available other disciplinary items in Part I, Item 11 of the ADV which can be found on the SEC’s website at www.adviserinfo.sec.gov. As UBS AMA LLC is under the ultimate control of UBS Group, it has U.S and non-U.S. affiliates that engage in a variety of financial services activities. UBS AMA LLC may be required to disclose certain disciplinary events involving those affiliates. In addition, such actions may require UBS AMA LLC to seek exemptive or other relief from the SEC or other regulators to permit it to continue to conduct its investment advisory business. There is no assurance that such relief will be granted or, if granted, what terms or conditions UBS AMA LLC may need to agree to with respect to its business as a result of the conduct of its business units and affiliates. Page 37 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 10: Other Financial Industry Activities and Affiliations Overview This section of the Brochure contains information about our financial industry activities and affiliations. We provide information about the material relationships and arrangements we have with advisory affiliates or any persons under common control with our UBS AMA LLC, including broker-dealers, investment companies and other pooled vehicles, affiliated investments advisers, financial planners, banking institutions and other similar entities. We identify if any of these relationships or arrangements creates a material conflict of interests with clients and discuss how we address these conflicts. Broker-Dealer registration UBS AMA LLC is not registered as a broker-dealer. One of its affiliates, UBS Asset Management (US) Inc., is a registered broker-dealer and a member of the Financial Industry Regulatory Authority ("FINRA") for the limited purpose of facilitating the distribution of collective investment vehicles, such as mutual funds, managed by UBS AMA LLC and its affiliates. A number of UBS AMA LLC’s management persons and personnel are also principals or registered representatives of UBS Asset Management (US) Inc. Futures Commission Merchant, Commodity Pool Operator, and Commodity Trading Advisor registration UBS AMA LLC is registered with the Commodity Futures Trading Commission ("CFTC") as a commodity pool operator ("CPO") and a commodity trading advisor ("CTA") and is a member of the National Futures Association ("NFA"). UBS AMA LLC is not registered as a Futures Commission Merchant (“FCM” ). Information on the registration status of specific investment funds is available upon request. UBS AMA LLC filed a notice of claim for exemption pursuant to CFTC Rule 4.7 in April 1996. Rule 4.7 exempts a CTA and a CPO who file a notice of claim for exemption from having to provide a CFTC-mandated Disclosure Document to certain highly accredited clients, defined as qualified eligible participants ("QEPs") who consent to their account being Rule 4.7 exempt QEP accounts. UBS AMA LLC has received consent for the 4.7 exemption and is not required to provide a Disclosure Document with respect to its Rule 4.7 exempt QEP accounts. PURSUANT TO THE EXEMPTION FROM THE COMMODITY FUTURES TRADING COMMISSION IN CONNECTION WITH ACCOUNTS OF QEPs, THIS BROCHURE IS NOT REQUIRED TO BE, AND HAS NOT BEEN, FILED WITH THE CFTC. THE CFTC DOES NOT PASS UPON THE MERITS OF PARTICIPATING IN A TRADING PROGRAM OR UPON THE ADEQUACY OR ACCURACY OF COMMODITY TRADING ADVISOR DISCLOSURE. CONSEQUENTLY, THE CFTC HAS NOT REVIEWED OR APPROVED THIS TRADING PROGRAM OR BROCHURE. The following affiliates of UBS AMA LLC are registered with the CFTC as FCMs, CPOs, and/or CTAs: UBS Securities LLC (FCM, CPO, and CTA), and UBS Financial Services Inc. (FCM). Use of related persons—material relationships and arrangements UBS AMA LLC is an indirect wholly owned subsidiary of UBS, a Swiss corporation headquartered in Zurich and Basel, Switzerland. As a large, globally diversified financial services firm, UBS' direct and indirect affiliates and related persons include various broker-dealers, FCMs, CPOs, CTAs, investment advisers, pension consultants, banking organizations and other financial services firms. UBS AMA LLC has arrangements that are material to its advisory business with UBS and certain of its affiliates. UBS AMA LLC may also have arrangements to purchase certain investment advisory, brokerage and incidental services, corporate finance Page 38 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A advisory services and foreign exchange services from some UBS affiliates. A list of certain UBS subsidiaries is available in the UBS annual report, which is publicly available at www.ubs.com. • Affiliated Broker-Dealers, Municipal Securities Dealers and Government Securities Broker-Dealers: The following affiliates of UBS AMA LLC are broker-dealers registered in the United States: UBS Securities LLC; UBS Financial Services Inc.; UBS Asset Management (US) Inc.; and UBS Fund Services (USA) LLC. Certain of those affiliates are also registered as municipal securities dealers and/or government securities broker-dealers. In addition, UBS AMA LLC has numerous broker-dealer affiliates operating outside the United States. A complete list of affiliated broker-dealers is available to clients upon request. If consistent with applicable law and contractual arrangements with clients, some transactions for client accounts may be executed through our broker-dealer affiliates, which may earn commissions in connection with such transactions. These affiliates are compensated by clients for executing the transactions; however, UBS AMA LLC has no agreements with its affiliates that obligate it to direct client transactions to such affiliates and UBS AMA LLC receives no compensation from its affiliates in connection with such transactions. All such transactions are executed in compliance with our duty to seek best execution, the Advisers Act, and other applicable law. UBS AMA LLC does not generally act as principal or broker in connection with client transactions. In connection with transactions in which our affiliated broker-dealers may act as principal, UBS AMA LLC, in compliance with applicable regulatory requirements, will disclose to the advisory client the terms of the trade, that the trade will be conducted on a principal basis and obtain the client’s informed consent prior to completion of each such transaction. UBS AMA LLC will recommend that a client engage in such a transaction only when we believe that we will satisfy our duty to seek best execution. UBS AMA LLC and our affiliates will not engage in principal transactions for clients subject to the Investment Company Act or ERISA, except to the extent permitted by exemptive order, applicable regulation or prohibited transaction exemption. UBS AMA LLC’s affiliated broker-dealers may, subject to applicable law, execute agency cross transactions on behalf of clients only if appropriate client consent is obtained and the required disclosure is ma de. An "agency cross transaction" is a transaction in which one of our affiliates acts as broker for clients on both sides of the same transaction and receives a commission from each client. Since our affiliate may receive compensation from parties on both sides of such transactions, UBS AMA LLC and its affiliate may have a potentially conflicting division of loyalties and responsibilities. Consent to agency cross transactions may be revoked by a client at any time by written notice to UBS AMA LLC. UBS AMA LLC may execute securities and futures transactions with broker-dealers that do not have their own clearing facilities and who may clear such transactions through an affiliate of ours. In such cases, our affiliate will receive a clearing fee. UBS AMA LLC’s affiliates have direct or indirect interests in electronic communication networks and alternative trading systems (collectively "ECNs"). UBS AMA LLC, in accordance with its fiduciary obligation to seek best execution, may execute client trades through ECNs in which its related persons have, or may acquire, an interest. A related person may receive compensation based upon its ownership percentage in relation to the transaction fees charged by the ECNs. UBS AMA LLC will execute through an ECN in which a related person has an interest only in situations where we believe such transactions will be in the best interests of our clients and the requirements of applicable law have been satisfied. In accordance with Section 11(a) of the Securities Exchange Act of 1934, as amended, and the rules thereunder, UBS AMA LLC’s affiliates may effect transactions for our client accounts on a national securities exchange of which an affiliate is an equity owner and/or a member and may retain compensation in connection with those transactions. Page 39 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A UBS AMA LLC may effect transactions through an affiliate on behalf of clients on an agency basis. For clients with respect to which we are a "fiduciary" as defined in ERISA, such transactions will be effected in accordance with the terms of Prohibited Transaction Exemption 86-128 or other applicable prohibited transaction exemptions. UBS AMA LLC and its affiliates are authorized to effect agency transactions through an affiliated broker- dealer for its clients that are registered investment companies (the "Mutual Funds") pursuant to procedures adopted in accordance with Rule 17e-1 under the Investment Company Act (and approved by the Mutual Funds' Boards of Directors/Trustees). Rule 17e-1 is intended to ensure that all brokerage commissions paid by the Mutual Funds are reasonable and fair. Further, any transactions between the Mutual Funds and any other advisory account for which we also act as investment adviser are effected consistent with the requirements and conditions of Rule 17a-7 under the Investment Company Act. UBS AMA LLC may also effect "cross" transactions between client accounts in which we will cause one client to purchase investments held by another client of ours. Such transactions are only conducted in accordance with applicable law when we deem the transaction to be in the best interest of both clients and at a price determined by reference to independent market conditions, and wh ich we believe to constitute "best execution" for both clients. We will effect cross transactions with any client subject to ERISA only as permitted by ERISA Section 408(b)(19) or other applicable prohibited transaction exemption. With respect to Mutual Funds, such “cross” transactions would be subject to procedures adopted in accordance with Rule 17a-7 under the Investment Company Act (and approved by the Mutual Funds’ Boards of Directors or Trustees or Conflicts Review Board). • Investment Companies and Other Pooled Investment Vehicles: UBS AMA LLC is the investment adviser or sub-adviser and/or administrator for various investment companies registered under the Investment Company Act, as well as pooled investment vehicles exempt from registration under the Investment Company Act, including private investment companies, offshore funds and CLOs. Below is a list of Registered Funds managed by UBS AMA LLC, as of the date of this Brochure. Certain employees of UBS AMA LLC may be officers and/or directors/trustees of the funds listed below. DISCLAIMER: THE INFORMATION PROVIDED IN THIS BROCHURE IS INTENDED SOLELY FOR COMPLYING WITH FORM ADV DISCLOSURE REQUIREMENTS. THIS BROCHURE DOES NOT CONSTITUTE AN OFFER TO SELL OR A SOLICITATION OF AN OFFER TO BUY ANY SECURITIES. NOTHING IN THIS BROCHURE SHALL LIMIT OR RESTRICT THE PARTICULAR TERMS OF ANY SPECIFIC OFFERING. OFFERS WILL BE MADE ONLY TO QUALIFIED INVESTORS BY MEANS OF A PROSPECTUS OR CONFIDENTIAL PRIVATE OFFERING MEMORANDUM PROVIDING INFORMATION AS TO THE SPECIFICS OF THE OFFERING. NO OFFER OF ANY INTEREST IN ANY PRODUCT WILL BE MADE IN ANY JURISDICTION IN WHICH THE OFFER, SOLICITATION OR SALE IS NOT PERMITTED, OR TO ANY PERSON TO WHOM IT IS UNLAWFUL TO MAKE SUCH OFFER, SOLICITATION OR SALE. • Registered Investment Companies: Each of the following investment company groups offer one or more open-end or closed-end investment companies registered under the Investment Company Act to qualifying investors: o The UBS Funds o PACE Select Advisors Trust. Please note that in most cases, various sub-advisers manage the investment portfolios of the funds under PACE Select Advisors Trust. o Master Trust. Please note that interests in Master Trust are issued solely in private placements transactions that do not involve a "public offering" within the meaning of Section 4(2) of the Securities Act of 1933. Investments in Master Trust may only be made by "accredited investors" within the meaning of Regulation D under the Securities Act of 1933. o SMA Relationship Trust o UBS Investment Trust o UBS Series Funds Page 40 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A o UGA A&Q Funds – A&Q Multi-Strategy Fund, A&Q Technology Fund, LLC, A&Q Long/Short Strategies Fund LLC o Credit Suisse High Yield Credit Fund Inc. o Credit Suisse Asset Management Income Fund, Inc. o Credit Suisse Floating Rate High Income Fund o Credit Suisse Strategic Income Fund • Other Pooled Investment Vehicles: UBS AMA LLC offers various pooled investment vehicles through each of its business units. A complete list of fund vehicles can be provided upon request. • Other Investment Advisers: UBS AMA LLC is one of the investment advisory entities within the UBS Asset Management division. RE-US and Farmland are also SEC-registered investment advisers in the division. UBS AMA LLC presents multi-asset class marketing materials to certain prospective clients that may include materials for RE-US and Farmland, along with strategy or fund information related to various UBS AMA LLC products or services, in the same presentation. Such presentations would contain both GIPS compliant and non-GIPS compliant materials. In addition, UBS Asset Management division includes various “Participating Affiliates” operating outside the United States that provide investment management services. UBS AMA LLC may, in its discretion, utilize personnel of Participating Affiliates to perform certain advisory and other functions (including portfolio management and placing trades on behalf of clients). The employees of such Participating Affiliates may provide portfolio management, research, financial analysis, order placement, and other services on behalf of UBS AMA LLC to its U.S. clients. Such employees will be acting as associated persons of UBS AMA LLC in providing such services under the direct supervision and oversight of UBS AMA LLC. UBS AMA LLC remains responsible for the advice and services provided, and clients will not pay additional investment advisory fees as a result of such advice and services being rendered by such associated persons, absent disclosure and express client consent. UBS AMA LLC has a Global Services Agreement in place with its Participating Affiliates, which is structured in accordance with a series of SEC no-action relief letters mandating that Participating Affiliates remain subject to the regulatory supervision of both UBS AMA LLC and the SEC in certain respects. Under the terms of the Global Service Agreement among certain domestic and foreign entities within the UBS Asset Management division, the parties agree to provide such advice and assistance to each other as is reasonably necessary to permit the others in the division to render investment advice and related services to UBS AMA LLC client accounts. Such advisory affiliates include, but are not limited to: o UBS Asset Management (Australia) Ltd. o UBS Asset Management (Canada) Inc. o UBS Asset Management (Europe) S.A. (including participating branch offices) o UBS Asset Management (Hong Kong) Limited o UBS Asset Management (Japan) Limited o UBS Asset Management (Shanghai) Limited o UBS Asset Management (Singapore) Ltd. o UBS Asset Management Switzerland AG o UBS Asset Management (Taiwan) Ltd. o UBS Asset Management Trust Company o UBS Asset Management (UK) Ltd. o UBS Asset Management Credit Investments Group (UK) Ltd. o UBS Farmland Investors, LLC o UBS Realty Investors, LLC Advisory affiliates that provide fund administration services outside the United States, include, without limitation: Page 41 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A o UBS Asset Management Funds Ltd. o UBS Fund Management (Ireland) Ltd. o UBS Fund Management (Switzerland) AG o UBS Rui Yuan Investment Fund Management (Shanghai) Limited • Financial Planners: Affiliates of UBS AMA LLC, including UBS AG and UBS Financial Services, may provide financial planning services to their clients. • Banking Institutions: UBS AMA LLC is a member of the UBS Asset Management division of UBS Group AG, a Swiss financial organization. Affiliated banking institutions include the following wholly owned subsidiaries of UBS Group AG: UBS AG, a Swiss banking organization and a financial holding company under the US Bank Holding Company Act; and UBS Bank USA, National Association, a national bank. UBS Asset Management Trust Company, an Illinois chartered non-depository trust company, is an affiliate of UBS AMA LLC. Certain UBS Asset Management employees are also officers of the Trust Company. In addition, UBS AM provides investment sub-advisory services to the Trust Company with respect to certain CITs. The Trust Company provides fiduciary services to employee benefit retirement plans and serves as the investment manager and trustee for various CITs, including UBS (US) Group Trust and certain closed - end CITs. The CITs are investment vehicles through which ERISA retirement plans, governmental plans, and other eligible retirement plans commingle their assets for investment purposes. The CITs are exempt from registration under the Investment Company Act. • Pension Consultants: UBS AMA LLC may provide pension consulting services to certain of its clients, subject to compliance with applicable rules and regulations, including ERISA. In addition, certain of our affiliates, including UBS Financial Services, may also provide pension consult ing services to their clients. • Limited Partnership Sponsorships: UBS AM is the general partner of certain private equity limited partnerships in which clients were previously solicited to invest, but which are no longer open to new investors. For certain of those partnerships, UBS AM has engaged Adams Street Partners LLC, an unaffiliated registered investment adviser, as sub-adviser. • Recommending or selecting other investment advisers and sub-advisers: UBS AMA LLC may recommend or select other investment advisers or sub-advisers for clients; however, we do not receive direct or indirect compensation from those advisers or sub-advisers. • Other: Certain subsidiaries of UBS Group AG, including UBS Business Solutions US LLC, UBS Business Solutions AG, UBS Business Solutions Poland sp. z.o.o., and UBS Business Solutions (India) Private Limited provide certain services to UBS's affiliates and subsidiaries, including UBS AMA LLC. Services currently include Finance, Risk Control, Compliance, Legal, Human Resources, Technology, and Operations. Additional considerations As described previously, UBS AMA LLC will generally be deemed a related party with respect to UBS Group, including its various directly and indirectly owned subsidiaries. These entities engage in a variety of financial services activities. In the regular course of business, UBS Group and its affiliates may engage in activities where their interests or the interests of their clients conflict with the interests of UBS AMA LLC’s clients. The potential conflicts of interest that may arise due to the broad spectrum of activities engaged in by the UBS Group, UBS AMA LLC, and its affiliates are described in detail in the offering documents of portfolios or funds advised by UBS AMA LLC. These potential conflicts, which may arise in the regular course of business include, but are not limited to, the following: Page 42 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A (i) UBS Group and its affiliates may receive investment banking fees from portfolio companies and other parties involved in transactions with UBS AMA LLC’s clients; (ii) UBS Group or its affiliates may act, or may seek to act, as a financial advisor to third parties in connection with the sale or purchase of securities or businesses meeting the investment objectives of UBS AMA LLC’s clients, which may prevent UBS AMA LLC’s clients from investing in the securities or businesses being sold; (iii) UBS Group and its affiliates may act, or may seek to act, as financial adviser to a potential third- party buyer of a potential investment that UBS AMA LLC’s clients are also seeking to buy, or a potential buyer of an existing portfolio company or any assets or businesses held by an existing portfolio company; (iv) UBS AMA LLC’s clients may be offered an opportunity to make an investment (a) in connection with a transaction in which UBS Group, its affiliates or one of their clients (or one of UBS AMA LLC’s own clients) is expected to or seeks to participate or (b) in a company in which UBS Group, its affiliates or one of their clients (or one of UBS AMA LLC’s own clients) already has made, or concurrently will make or seek to make, an investment; (v) a client of UBS AMA LLC may hold the same or a different class of securities of the same issuer relative to another client of UBS AMA LLC or the same or a different class relative to UBS Group, its affiliates, or one of their clients. It is possible that in connection with an insolvency, bankruptcy, reorganization, or similar proceeding, a client account will be limited (by applicable law, courts or otherwise) in the positions or actions it will be permitted to take due to other interests held or actions or positions taken by UBS AMA LLC or other clients of UBS AMA LLC, or of UBS Group, its affiliates or one of their clients (vi) purchases or sales of securities, assets, or businesses whose securities are held by a client of UBS AMA LLC may be made from or to UBS Group, a UBS Group affiliate or one of their clients (or another client of UBS AMA LLC); (vii) proceeds from the sale of securities by one of UBS AMA LLC’s clients may be used to repay a loan to the issuer from UBS Group, a UBS Group affiliate or client (or to one of UBS AMA LLC’s other clients); (viii) UBS Group and its affiliates may make investments or undertake investments on behalf of their clients that are similar to the investments intended to be made by UBS AMA LLC’s clients; (ix) UBS AMA LLC’s clients may enter into arrangements to acquire or sell debt or equity investments, borrow funds, or guarantee borrowings of funds from, or enter into hedging or other transactions with, UBS Group or its affiliates; (x) UBS Group and its affiliates have, and may in the future develop, relationships with a significant number of companies and their senior managers, including relationships with clients who may hold or may have held investments similar to the investments intended to be made by UBS AMA LLC’s clients; (xi) employees of UBS Group may receive remuneration as a result of cross-divisional transactions and referrals made to its affiliates; (xii) UBS Group and its affiliates may make investments on behalf of clients into portfolios or funds managed, advised or sponsored by UBS Group or one of its affiliates; and (xiii) UBS Group and its affiliates may have financial interests that diverge from those of UBS AMA LLC’s clients and may take actions harmful to UBS AMA LLC’s clients. UBS AMA LLC has implemented policies and procedures reasonably designed to identify, and to mitigate or avoid, the potential conflicts associated with the range of activities conducted by UBS Group. These policies include electronic and physical barriers to prevent the misuse of confidential information within UBS Group. Page 43 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A CIG, in managing client portfolios, may acquire investments representing parts or levels of an issuer’s capital structure different than those held in other client portfolios. CIG acknowledges there will be conflicts of interest in managing such investments in distressed situations. For example, CIG, on behalf of a client, may elect to serve on creditors’ committees, official or unofficial, equity holders’ committees or other groups to ensure preservation or enhancement of the client’s position as a creditor or equity holder in bankruptcy or insolvency proceedings or otherwise be engaged in financial restructuring activities in a variety of capacities. Such activities may result in CIG receiving confidential information that may, as a result of applicable securities laws or the internal policies of UBS AMA LLC, limit or otherwise constrain CIG’s flexibility in purchasing or selling securities or other obligations with respect to all client portfolios. At times, CIG, in an effort to avoid such restrictions or limitations for client portfolios, m ay elect not to receive confidential information, which may be relevant to the client portfolios, that other market participants are eligible to receive or have received. However, CIG may choose to implement information barrier procedures to allow investments to be managed independently by preventing the transmission of private side information to those managing public side client holdings. These procedures are designed to balance the various investment interests of all clients during distressed situations, manage potential conflicts between clients, and satisfy fiduciary duties owed to all clients. Investment banking affiliates of UBS AMA LLC may advise buyers acquiring a distressed company, while UBS AMA LLC serves on the creditors’ committee of the company as a result of its clients’ equity or debt holdings of the company. UBS AMA LLC has established information barrier procedures to address these instances. In addition, other potential conflicts of interest may arise due to the activities of UBS AMA LLC and its personnel. These potential conflicts include, but are not limited to, the following: (i) personnel of UBS AMA LLC may serve as directors of certain companies in which UBS AMA LLC’s clients have an interest, and, in that capacity, will be required to make decisions that consider the best interests of the portfolio company rather than the individual interests of UBS AMA LLC’s clients; and (ii) personnel of UBS AMA LLC may serve in various other capacities and will devote such time to each of UBS AMA LLC’s clients as UBS AMA LLC, in its sole discretion, deems necessary to carry out the operations of each client effectively. UBS AMA LLC and its affiliates provide investment advisory and other services to various clients and may give advice or take other actions in the performance of those services to some clients that may differ materially from the advice given, or the timing or nature of actions taken, with respect to other clients. As noted above in Item 6, the receipt of performance fees by CIG or its affiliates creates a potential conflict of interest because CIG could benefit from disproportionately allocating investment opportunities to those client accounts subject to performance fees. CIG has adopted policies and procedures designed to ensure that investment opportunities are allocated fairly among eligible accounts (i.e., clients with similar investment strategies) over time. Expert research networks UBS AMA LLC may utilize expert network services to obtain market, sector, company, or other information. There may be a conflict of interest in such arrangements as the experts are financially incentivized to provide information in order to maintain their position within the network. UBS AMA LLC has procedures in place that seek to address such conflicts, including managing the risks of receiving inside information. Monitoring of conflicts of interest UBS AMA LLC has established policies and procedures to identify and address potential conflicts of interest. Any conflicts of interest that arise between one of UBS AMA LLC’s clients and UBS Group and its affiliates or their clients (or another client of UBS AMA LLC) will be discussed and resolved on a case-by-case basis Page 44 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A by senior officers of UBS Group and its affiliates and representatives of UBS AMA LLC, or internally by UBS AMA LLC, as applicable. Any such discussions will take into consideration the interests of the relevant parties and the circumstances giving rise to the potential conflict. Potential conflicts will not necessarily be resolved in favor of CIG’s clients or any one of UBS AMA LLC’s clients. To the extent possible, UBS AMA LLC will seek to engage in arm’s-length transactions in which UBS Group and its affiliates have a direct or indirect financial interest. Direct lending origination conflict A conflict may arise when Funds and Accounts advised by CIG have lent funds to a borrower and a direct lending opportunity arises whereby a direct lending investment by CIG would be extended to the same borrower (e.g., providing additional financing, supporting the refinancing of existing debt, etc.). In such a case, this transaction could be viewed as potentially benefiting either the Funds and Accounts with current holdings or those involved in the direct lending financing, positions in the borrower. CIG maintains procedures to address this potential conflict, including ensuring that the transaction is in the best interest of our clients. Additional information regarding this potential conflict can be found in the applicable Governing Document. Page 45 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Overview This section of the Brochure contains a summary of our Code of Ethics. We also describe circumstances where we may recommend, buy, or sell securities for client accounts in which we (or a related person) may have a material financial interest. This description includes information on the conflicts of interests that may arise and how we address these conflicts. Code of Ethics: Proprietary and employee securities transactions UBS AMA LLC has adopted a Code of Ethics ("Code") designed to meet the requirements of Rule 204A-1 of the Advisers Act and Rule 17j-1 of the Investment Company Act and which sets forth ethical standards of business conduct required from all employees, including compliance with applicable securities laws. The Code is intended, among other things, to ensure that personal investing activities by employees and certain o f their family members are consistent with our fiduciary duty to clients. The Code sets forth policies and procedures on identifying, escalating, and addressing any potential or actual conflicts of interest that may present themselves between employees, officers and directors of UBS AMA LLC and UBS AMA LLC’s clients. The Code incorporates the following general principles which all employees are required to uphold: • UBS AMA LLC and its employees must at all times place the interest of its clients ahead of their own; • No principal or employee of UBS AMA LLC may buy or sell securities for his or her personal account portfolio(s) where their investment decision is a result of information received as a result of his or her employment unless the information is also available to the investing public; • All employees are required to act in accordance with all applicable federal and state regulations governing registered investment advisory practices; and • All employees are required to report violations of the Code to the Chief Compliance Officer. Unless specifically exempted under Rule 204A-1, our Code generally requires employees to obtain written preclearance for securities transactions in personal accounts. UBS AMA LLC views certain transactions as especially likely to create a conflict of interest with its clients, and therefore prohibits employees from engaging in the following types of transactions: (i) short sales of shares of UBS and certain related financial instruments; (ii) purchase or sale of futures that are not traded on an exchange, as well as options on any type of futures; and (iii) generally IPOs. Investments in limited offerings are permitted, with preclearance for any new investments or additional capital investments. UBS AMA LLC also permits options trading and investments in IPOs under certain conditions and with preclearance. All employees of UBS AMA LLC and our affiliates may from time to time have acquired or sold, or may subsequently acquire or sell, for their personal accounts, securities that may also be held, or have been purchased or sold, for the accounts of our clients. Our Code imposes certain "lockout" periods whereby certain employees may not be able to trade in a particular security if we recommend a transaction in that security for clients. These lockout periods are subject to certain exceptions upon approval by a compliance officer. Employees also are generally required to hold securities, including mutual funds we advise or sub-advise, for a period of at least 30 days. Additionally, to ensure that employees are not distracted from servicing advisory clients, employees are discouraged from engaging in any personal trading activity that consumes excessive time and attention or interferes with the performance of their duties for UBS AMA LLC or UBS AMA LLC Page 46 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A clients. The trading restrictions generally do not apply to accounts in which an employee has an interest, but which is subject to a discretionary investment management agreement, whether with an affiliate or an unaffiliated manager. Additionally, our employees may be investors in certain pooled vehicles for which we or an affiliate act as investment adviser. For purposes of the Code, such investment vehicles are treated as clients and are not subject to the personal trading restrictions described above. All UBS AMA LLC employees are required, upon hire and at least annually, to confirm receipt of the Code and to attest their compliance with the policies and procedures therein. Employees are also required to: (i) disclose any covered personal accounts1, as defined in the Code, within 10 calendar days of becoming an employee of UBS AMA LLC, including certain immediate family member accounts2; (ii) submit initial and annual holdings reports disclosing their personal securities holdings in any covered personal accounts; (iii) submit quarterly reports disclosing all personal securities transactions in any covered personal accounts; and (iv) report any violations of the Code promptly to Head of Compliance of the applicable business unit. Holdings and transactions may be periodically reviewed by UBS control functions, and any violations are appropriately escalated to the Head of Compliance of the applicable business unit and resolved in accordance with Rule 204A-1, Rule 38a-1, UBS AMA LLC policies and any other federal securities laws, as applicable. UBS AMA LLC has also established separate policies and procedures designed to detect other conflicts of interest and prevent insider trading. All employees are provided with such policies and are required to complete comprehensive compliance training on at least an annual basis. UBS AMA LLC will provide a copy of our Code of Ethics to any client or prospective client upon request. Participation or interest in client transactions General UBS AMA LLC may purchase or sell, or recommend for purchase or sale, for our investment advisory clients investments of companies: (i) with respect to which our affiliates act as an investment banker or financial adviser; (ii) with which our affiliates have other confidential relationships; (iii) in which our affiliates maintain a position or make a market; or (iv) in which the affiliate or its officers, directors or employees own investments or otherwise have an interest if it determines such transactions to be in the best interest of its clients. Except to the extent prohibited by law or regulation or by client instruct ion, UBS AMA LLC may recommend to our clients, or purchase for our clients, investments of issuers in which UBS has an interest. We may also invest in or recommend for purchase for our clients' investments issued by a company for whose pension plan we act as investment manager or otherwise with whom we have a client relationship (i.e., ERISA clients). To minimize potential conflicts of interests, UBS AMA LLC’s investment advisory business, is structured as a separate and distinct business from our affiliates that conduct banking, investment banking, broker -dealer (other than pooled fund distribution), wealth management or a variety of other financial services businesses. In providing such services, our affiliates may have access to material, non-public information. In order to prevent the improper communication of such inside information, UBS AMA LLC and its affiliates have established policies and procedures designed to prevent the misuse of such information and the spread of such information within or across business divisions. UBS AMA LLC’s business processes and information systems are designed to prevent sensitive information regarding affiliates’ businesses from being shared with or accessed by our personnel and to prevent sensitive information regarding our business from bei ng shared with or accessed by our affiliates. However, despite these information barriers, as a result of applicable law or potential conflicts of interests, UBS AMA LLC may be precluded from effecting or recommending 1 A “covered personal account” includes any securities account (held at a broker -dealer, transfer agent, investment advisory firm, bank or other financial services firm) in which an employee has a beneficial interest or over which the employee has investment discretion or other control or influence. 2 Immediate family members, as defined by the SEC, include any child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law and shall include adoptive relationships. Page 47 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A transactions in particular securities for its clients that we may otherwise believe are an attractive investment. Material, nonpublic information may also become available to UBS AMA LLC through our client relationships or other activities. This information will not knowingly be passed on to our investment advisory clients, or used for our or their benefit, or for any other purpose. The highest priority of every investment professional at UBS AMA LLC is to pursue each client’s investment goals through independent analysis and portfolio management. At all times, our research, security selection and trade execution are performed strictly and solely in adherence with the investment principles established independently by UBS AMA LLC, and in full compliance with all applicable banking, securities and fiduciary laws and regulations. To the extent we cause transactions for client accounts to be executed through affiliates (which will only be done in compliance with applicable law, as described above), UBS AMA LLC receives no additional remuneration with respect to such transactions. The compensation of our personnel is dependent solely on the results of our investment advisory business. From time to time, UBS AMA LLC and our affiliates may engage in cross marketing their services to clients and prospects. As noted above, UBS AMA LLC and our affiliates have policies and procedures in place to prevent the improper flow of information to or from UBS AMA LLC as a result of such cross-marketing opportunities. UBS Asset Management and our affiliates have relationships with a number of clients who, directly or through one or more affiliates, issue publicly traded securities. UBS AMA LLC may, in compliance with client investment guidelines and applicable law, purchase on behalf of our clients securities issued by another client. UBS Asset Management has a number of policies and procedures designed to manage this potential conflict of interest. As a result of differences in client objectives, strategies and risk tolerances, UBS AMA LLC may give different advice or make different recommendations to different clients that are authorized to invest in the same securities. In addition, our investment advice may differ from advice given by other business divisions within UBS or by other portfolio managers of UBS, as our investment advisory business is structured as a separate and distinct business from our affiliates that conduct banking, investment ban king, broker-dealer (other mutual fund distribution), wealth management, investment management or a variety of other financial services businesses. Conflicts exist when UBS AMA LLC and/or our affiliates invest, on behalf of our clients, in more than one part of the capital structure of the same issuer. UBS AMA LLC has a number of policies and internal controls designed to manage this potential conflict of interest. The underwritings section below further addresses one of these types of conflicts, where our affiliates may be engaged in the offering of a security which UBS AMA LLC may purchase on behalf of our clients. CIG expects to execute trades through its related persons on both a principal and agency basis, as discussed in further detail below. All such activities will be conducted in accordance with the CIG’s duty to seek best execution for its clients and otherwise in accordance with applicable law, including Section 206 of the Advisers Act and the rules thereunder. These activities, if required or appropriate, will include appropriate disclosure to and receipt of consent from an independent source such as a conflicts review service provider, an advisory committee, an independent adviser, or an authorized representative of the relevant client. Further, when engaging in such transactions, CIG will seek to comply, as applicable, with the Advisers Act, the Investment Company Act, the ERISA, and/or other applicable laws, rules or regulations, including any interpretations, modifications, exemptions or other relief or permission from or by the SEC, SEC staff, the U.S. Department of Labor (the “DOL”), DOL staff or other authority with appropriate jurisdiction. UBS AMA LLC and CIG have established policies, procedures and disclosures designed to address and monitor potential conflicts of interest arising in connection with trading between accounts of its clients and UBS AMA LLC and its affiliates. Page 48 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Underwritings In conformance with clients’ investment objectives and subject to compliance with applicable law, CIG may purchase securities for client accounts during an underwriting or other offering of securities in which an affiliated broker-dealer acts as a manager, co-manager, underwriter or placement agent, or receives a benefit in the form of management, underwriting, or other fees paid to members of an underwriting syndicate. Affiliates of ours may act in other capacities in such offerings for which a fee, compensation, or other benefit will be received. From time to time, our affiliates will be current investors in, or lenders to, comp anies engaged in an offering of securities which we may purchase on behalf of clients, and the proceeds of such purchases may be used to pay off or retire the interests of our affiliates. Such purchases may provide a direct or indirect benefit to our affiliates acting as a selling shareholder, through the return of capital or otherwise. UBS AMA LLC may also participate in structured fixed income offerings of securities in which a related person may serve as trustee, depositor, originator, arranger, service agent or other service provider in which fees will be paid to such related person. Further, a related person may act as originator and/or servicing agent of loans or receivables for a structured fixed income offering in which we may invest client assets. Participation in such offerings may directly or indirectly relieve obligations of related persons. For clients subject to ERISA, such investments will be made in accordance with the terms of applicable prohibited transaction exemptions. Principal Transactions To the extent permitted by applicable law, CIG may enter into transactions and buy or sell securities or instruments for the account of certain clients when one or more affiliates of UBS AMA LLC acts as principal or otherwise makes a market in such securities or investments or when an affiliate is the underwriter of such securities or investments. Use of such affiliates will create conflicts of interest due to the conflicting loyalties between the affiliate and CIG’s clients. To mitigate this conflict of interest, when CIG enters into a principal transaction it employs either a designated Conflicts Review Board, the independent board of directors of the related Fund or Account or an authorized representative of the client to obtain consent to the transaction. In addition, a review process is used to ensure that consent for the transaction is received and complies with applicable law. Failure to obtain consent may result in unwinding or “breaking” the trade at the expense of CIG. However, in selecting any affiliate, CIG will use the same criteria as it uses to select any other broker or dealer, including a fiduciary obligation and to seek best execution. Cross Transactions CIG may buy or sell securities or investments for clients when an affiliate of UBS AMA LLC serves as broker for both the CIG’s client and the party on the other side of the transaction. CIG also may direct a client to sell investments to another client, subject to applicable guidelines. If CIG engages in such transactions, it will receive no compensation in connection therewith and will seek to comply with applicable law. To the extent an affiliated broker-dealer of UBS AMA LLC receives compensation in connection with such a transaction, CIG will disclose the dual capacity in which the affiliated broker is acting and will obtain the consent of the client prior to effecting the transaction, unless the client, prior to effecting the transaction, has granted permission to engage in these types of transactions in accordance with Rule 206(3)-2 under the Advisers Act. Cross transactions include trades between Private Funds or Accounts advised by CIG or its affiliates. Cross transactions will enable CIG to purchase or sell a block of securities or other instruments for a client at a set price and possibly avoid an unfavorable price movement that may be created through entrance into the market with such purchase or sell order. In all cases, if CIG engages in a cross transaction, it will do so if it believes it is in the best interest of all clients participating in the transaction. This may have a potentially conflicting division of responsibilities to both parties to a principal or cross transaction. For additional information concerning the interests of CIG and its affiliates in client transactions, see Item 10 above. Investments in funds When permitted by applicable law and the client's investment guidelines, and when considered by UBS AMA Page 49 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A LLC to be in the best interests of a client, we may recommend to clients and we may invest assets of clients' accounts in various closed-end and open-end investment companies, collective investment trusts and other pooled investment funds managed by CIG or an affiliate, including without limitation minority or majority positions in certain classes of CLOs and CLO warehouses. UBS AMA LLC may or may not receive compensation for such services from the funds. As previously noted, under certain circumstances and where permissible by regulations, the investment of an investor’s assets in a fund may result in multiple layers of fees paid to CIG and such fund. Any such layered fees would be disclosed in the Governing Documents associated with the investment. UBS AMA LLC, its affiliates, CIG clients, and/or CIG employees (“UBS CLO Investors”) may invest and trade in securities issued by CIG-managed CLOs. These investments by UBS CLO Investors may create actual or potential conflicts of interest as their economic interests may differ from and be adverse to the interests of other CLO investors. When UBS CLO Investors own CLO securities, such investors may exercise the rights associated with those securities, including voting rights. When acting on behalf of client s, CIG is required to act in the best interests of the CIG client holding the securities, which may conflict with the interests of other CLO investors. For example, UBS CLO Investors may vote their securities, or CIG may recommend how CIG clients vote, in a manner that results in an early redemption of CLO securities or amendments to the CLO transaction documents, even if those actions are not in the best interests of other investors. UBS AMA LLC, on behalf of clients, may invest in private equity offerings in which an advisory affiliate and/or related person may also invest. With respect to such investments, our advisory affiliates and/or related persons may buy and sell at times and prices which may be more or less favorable than prices paid or received by our clients. Page 50 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 12: Brokerage Practices Overview This section of the Brochure contains information regarding our brokerage practices, including the trade execution services we provide to clients in selecting broker-dealers and other execution counterparties relative to their competitive bid/ask execution levels and in negotiating commission rates and other transaction costs on behalf of our client accounts. We also discuss the brokerage and research services we receive in connection with client securities transactions. Additionally, we discuss the aggregation an d allocation of client orders and how we address errors. Selection of Brokers and Dealers; Commission Rates CIG has a fiduciary duty to its clients to seek best execution when effecting transactions on their behalf. In executing, placing or transmitting orders for its clients, CIG seeks to fulfill its best execution fiduciary responsibilities by taking sufficient or reasonable steps to obtain the best possible results. As part of best execution, CIG takes into account a variety of factors which include, without limitation , execution criteria, execution factors, execution venues, research, and where applicable, counterparty selection, in addition to any other relevant factors. In the course of executing client transactions, CIG may also utilize the execution services of a counterparty (including a related person) rather than trading directly with a market maker for certain financial instruments, when CIG believes it is in the best interest of a client. Each security, loan, or derivative transaction will be placed with specific broker-dealers or other counterparties selected by CIG with the overriding goal of receiving “best execution” at a fair, competitive bid/ask execution brokerage cost. CIG will seek to select broker-dealers (which may include its affiliates) and other trading counterparties based on a variety of factors, including, without limitation, portfolio characteristics (including portfolio investment guidelines/restrictions and regulations that may affect how orders are placed for the client), the characteristics of the order, the characteristics of the financial instruments that are the subject of that order, execution capabilities with respect to the relevant type of order, commissions charged, the reputation and financial condition of the firm, and research or brokerage services provided by the counterparty. The use of affiliated broker-dealers creates certain conflicts of interests, including the fact that the affiliate and certain of its employees may receive additional compensation . CIG will determine the overall reasonableness of the bid/ask execution levels, brokerage commissions or dealer spreads and other transaction costs on client transactions by taking into account various factors, including, but not limited to, current market conditions, size and timing of the order, depth of the market, bid and ask levels, per share price, difficulty of execution, the time taken to conclude the transaction, the extent of the broker-dealer’s commitment, if any, of its own capital, and the transaction size. In the course of executing client transactions, and when in the best interests of our clients, we may utilize the execution services of a broker-dealer (including a related person) other than the market-maker for certain over-the- counter transactions. These approaches bear different costs that we take into consideration as part of our execution strategy in the best interest of our clients. Leveraged loans and distressed debt transactions are subject to settlement periods in excess of the typical settlement periods for securities (i.e., publicly traded equities, corporate bonds). Settlement periods for leveraged loans range from seven days or longer. The seller is the owner of record until the settlement date and as such, is paid the requisite interest and fees from the administrative agent bank through that date. As part of the settlement process, the buyer is entitled to a certain portion of the requisite interest and fees based upon the standard industry settlement date ranges for secondary and primary loans. Should the actual settlement date go beyond the standard industry settlement date ranges referred to above for reasons not caused by the buyer or as a result of certain other defined exemptions, the buyer would be entitled to a certain portion of the requisite interest and fees for the settlement period beyond the industry standard date ranges. Page 51 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Soft Dollars CIG does not currently have any commission sharing agreements with any of its brokers and does not engage in soft dollar practices. However, if it did, commissions for the combination of execution and research services that meet CIG’s standards may be higher than for execution services alone or for services that fall below CIG’s standards. Further, CIG would only seek to receive brokerage or research services in connection with securities transactions in a manner consistent with the “safe harbor” provisions of Section 28(e) of the Securities Exchange Act of 1934, as amended. To the extent that CIG provides advisory services to multiple clients, research would be used to service all of CIG's clients, not just those paying for it, and the benefits would not necessarily be allocated proportionately to the accounts generating soft dollar credits. Trade Aggregation, Allocation and Errors With respect to clients that invest directly in investment securities or other assets, if CIG believes that the purchase or sale of an investment is in the best interest of more than one Fund or more than one Account, it may (but is not obligated to) aggregate the orders to be sold or purchased to obtain favorable execution or lower brokerage commissions, to the extent practicable and when permitte d by the Governing Documents, applicable laws and regulations. Although no specific method of allocation of tra nsactions (as well as expenses incurred in the transactions) is expected to be used, when trades are aggregated, the transactions, as well as the expenses incurred in the transactions, will be allocated by CIG according to procedures designed to seek to ensure that such allocation is fair and equitable over time and consistent with CIG's fiduciary duty and client guidelines in order to construct a fully invested portfolio (including its duty to seek to obtain best execution of trades). Aggregation of orders under this circumstance should, on average, decrease the costs of execution. Generally, each client that participates in an aggregated transaction will typically receive a price for the aggregated order in that investment on a given business day, by broker, with transaction costs shared pro rata based on each client's allocations to the relevant trade. Client accounts that may be aggregated may include Funds and Accounts managed by CIG's affiliates and accounts in which CIG and its affiliates and their respective officers, directors, agents or employees' own interests or may benefit directly or indirectly. Depending upon markets conditions, the aggregation of orders may result in higher or lower average prices paid or received. Orders which are not aggregated are entered at the market prices prevailing at the time of the transaction. Accordingly, trades that are not aggregated and entered at different times during the same day may result in different pricing. In addition, derivative transactions may be priced by the counterparty or pursuant to the respective documentation for the derivative transactions. Thus, the instruments in client portfolios may be priced at different levels as a result of the timing of execution. While CIG seeks to minimize the price disparity that may result, there can be no assurance that consistent pricing will be achieved among clients. Further, there is no assurance that clients with similar strategies will hold the same investments or perform in a similar manner. As noted below, CIG may not be able to aggregate transactions for clients who direct the use of a particular broker-dealer. In those instances, the client also may not benefit from any improved execution or lower commissions that may be available for such transactions. Similar to CIG's process to aggregate trades, allocations of investment opportunities are made in a manner which CIG deems to be fair and equitable to clients over time. Additionally, due to the nature of certain assets as well as specific client guidelines, a pro-rata allocation of trading opportunities is not always feasible and as a result such allocations are driven primarily by a number of factors, including client guidelines, Governing Documents, legal and tax considerations and CIG's internal investment procedures. Under certain circumstances, clients will not be charged the same commission or commission equivalent rates in connection with a bunched or aggregated order. The effect of the aggregation therefore, on some occasions, could either advantage or disadvantage a particular client. CIG's internal investment procedures are based in general on its overall view of market conditions relative to each portfolio including such factors as the nature and size of existing and other portfolios under management as the nature and size of existing holdings and Page 52 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A cash positions. For example, consideration may be given to Funds and Accounts which are ramping up or have sizable inflows or outflows of funds. Allocations may be made to client accounts managed in a similar manner in order to provide similar size exposure to investments. For more information about trade allocation practices for a particular Fund or Account, please refer to the applicable Governing Documents. Errors CIG's policies, procedures, and systems have been reasonably designed to minimize potential errors when managing client assets. While CIG employs policies and procedures to avoid errors, it should be noted that any policy or procedure developed could not possibly anticipate every potential error. For example, errors may occur in the investment decision-making process (e.g., a decision may be to purchase an investment or an amount of an investment that violates client guidelines), in the trading process (e.g., a buy order may be executed as a sell order or vice versa), or as operational or settlement errors. We endeavor to identify such errors at the earliest possible time, correct them as soon as practicable, including but not limited to reallocation, where appropriate and documentation. Depending on the type and severity of the error, the firm will typically undertake a review to determine whether a potential systemic weakness exists which requires adjustment in order to reasonably prevent reoccurrences of such errors. Broker or Dealer to be Used Most clients for whom CIG serves as investment adviser leave the selection of brokers or dealers to effect security and investment transactions to the discretion of CIG. In certain circumstances, including with respect to certain arrangements with third-party platforms, CIG may be instructed which brokers and dealers to use or not to use to execute securities transactions. The use of these designated brokers or dealers for brokerage purposes will, at all times, be subject to CIG's overriding goal of receiving “best execution” at a fair, competitive execution level or brokerage cost, for its clients, but it may not be possible for CIG to obtain for affected clients the lower rates or costs that might be obtainable if CIG had full discretion in the selection of the executing firm. Other Affiliated Transactions To the extent an affiliate is a participating underwriter in a syndicate, the affiliate may receive an indirect benefit from the purchase of shares, notes, securities, or investments, as applicable, from the underwritings by client accounts. Purchases from an underwriting syndicate in which an affiliate is a participating underwriter for clients who are subject to ERISA or the Investment Company Act will be made in compliance with the terms of Prohibited Transaction Exemption 75-1, or other applicable exemption, and Rule 10f-3 under the Investment Company Act, or other applicable rule, respectively. Secondary transactions between CIG client accounts and affiliate brokers are conducted in accordance with Section 206(3) of the Investment Advisers Act, and pursuant to policies and procedures designed to manage potential conflicts of interest. See Item 10: Other Financial Industry Activities and Affiliations, for further information on client consent requirements for principal and agency cross transactions with an affiliate broker. Page 53 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 13: Review of Accounts Overview This section of the Brochure describes our process for reviewing client accounts. We also describe the types of reports we provide to clients. Generally, CIG meets with each institutional client on a periodic basis, such as quarterly, semi -annually, or annually, in order to review investment strategy, performance, and administrative matters. CIG has processes in place for reviewing portfolio transactions for consistency with investment objectives, suitability, and that over time investment opportunities are fairly allocated among eligible accounts. There is considerable variation in the number of accounts assigned to different client portfolio managers, middle office professionals, and client coverage professionals, depending upon such factors as the type of account, the amount of assets under management, the nature of the investment goals and objectives and the location of the client. The nature and frequency of reporting to clients will vary depending upon a number of factors, including the investment program chosen by the client, the needs of the client, and the terms of the contract and other discussions between the client and CIG. Accounting and performance written reports are generated for each client on a periodic basis. CIG also reconciles every account independently against bank or brokerage statements to seek to ensure that income is properly credited to the account and that err ors will not go undetected. Generally, assets for which market quotations are readily available are assigned an independent mark and all other assets are assigned a “fair value,” subject to policies and procedures on valuation and oversight by the CIG Business Pricing Forum comprised of representatives from various functions, including CIG senior management. Page 54 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 14: Client Referrals and Other Compensation Overview This section of the Brochure describes our process for client referrals and related compensation arrangements. Affiliated or unaffiliated persons ("promoters") may, from time to time, refer, solicit, or introduce clients to CIG or investors in Private Funds advised by CIG. CIG, including through UBS AMA LLC, may compensate certain promoters consistent with the requirements of applicable law and regulation, including the Advisers Act as well as applicable state/local laws and regulations. For instance, we may pay a promoter a recurring fee, a one-time fee or a portion of the advisory fees or revenues that we earn for managing client or investor assets referred to us by the promoter. The costs of such referral fees are typically paid entirely by CIG, including through UBS AMA LLC, and do not result in any additional charges to the client or investor. However, certain referral arrangements may result in additional costs to a client or investor in addition to CIG's advisory fee. UBS AMA LLC's client service representatives and certain of our affiliates’ employees may receive incentive compensation, a portion of which may be attributable to solicitation or sales activities. UBS AMA LLC may also enter into arrangements to reimburse our and our affiliates’ employees for certain business expenses incurred in the solicitation of prospective clients or investors. All arrangements to pay promoters or placement agents for soliciting or doing business with a government client or investor must comply with the Advisers Act as well as any applicable state/local laws or regulations regarding the use of placement agents. CIG will conduct these activities in accordance with Rule 206(4)-1 under the Advisers Act (the “Marketing Rule”) which includes certain requirements when compensating persons who refer prospective clients or investors to CIG. Clients and investors receive specific disclosures related to these arrangements as required by the Marketing Rule and applicable law. In addition, UBS AMA LLC has implemented policies and procedures regarding political contributions and doing business with government entities in accordance with applicable laws and regulations, including Rule 206(4)-5 under the Advisers Act. All of our employees are required to receive written preclearance for any political contributions through our centralized compliance department to ensure compliance with appl icable political contribution restrictions. Furthermore, we do not normally allow political con tributions to be made by CIG (or UBS AMA LLC generally). UBS AMA LLC employees may occasionally refer clients to our affiliates and may be compensated by such affiliates, consistent with the requirements of applicable law and regulation. Where we have the discretion to allocate client assets we are managing to an affiliate for management as a sub-adviser, we will not receive any referral fees as a result of such allocation. Clients may also retain their own consultants to whom they pay fees directly. UBS AMA LLC and its affiliates may, from time to time, retain these consultants and pay them fees for various services provided to UBS AMA LLC such as pension consulting, market data, educational conferences, or separate research projects. Consultants performing due diligence on UBS AMA LLC’s investment processes may occasionally attend internal investment strategy meetings, provided that the consultant has executed a confidentiality agreement prior to attending the meetings. Page 55 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 15: Custody Overview This section of the Brochure describes our custody of client assets. Neither UBS AMA LLC nor CIG seeks to maintain direct custody of client assets. However, under Rule 206(4)- 2 under the Advisers Act, “custody” is broadly defined to also include holding indirectly client funds or securities or having any authority to obtain possession of them. In particular, in respect to CIG's clients, CIG would be considered to have custody either: (i) with respect to Accounts, because CIG is authorized under the client’s agreement with CIG to withdraw the client’s funds or securities main tained with a third-party custodian upon CIG's instruction to the third-party custodian; and (ii) with respect to Funds, CIG or an affiliate of CIG may serve in a capacity (such as general partner of a limited partnership, managing member of a limited liability company or a comparable position for another type of pooled investment vehicle, or trustee of a trust) that gives it legal ownership of or access to the Funds’ funds or securities. In order to avoid any conflict of interest that indirect custody of client assets may cause, CIG would, where relevant, comply with the applicable conditions of Rule 206(4)-2. In particular, CIG sends periodic account statements to our clients. We believe, after due inquiry, that our clients’ qualified custodians send periodic account statements to them as well. Additionally, Private Funds may engage independent public accountants to conduct an annual audit in accordance with Rule 206(4)-2. If the investors in such Private Funds receive audited financial statements prepared in accordance with U.S. generally accepted accounting principles ("GAAP"), within 120 days of each Private Fund’s fiscal year end (180 days for fund of funds), UBS AMA LLC, as the investment adviser to those Private Funds, is not subject to certain requirements of this rule. In limited instances for (i) Accounts for which CIG would have custody for reasons other than authority to pay advisory fees or (ii) Funds for which CIG is not required or is unable to timely deliver audited financial statements of the Fund to its investors, UBS AMA LLC would be required to undergo an annual surprise examination for such Funds or Accounts. The auditor's procedures for a surprise examination would include confirmation of assets and confirmation of contributions and withdrawals. In addition, for certain Funds, UBS Group affiliates may be utilized for custodial services and other securities transactions that could result in CIG being deemed to have custody of the Fund’s assets. When such situations arise, CIG's affiliates will engage a third-party accounting firm to perform an internal control review to satisfy the requirements of the Custody Rule. To ensure the safekeeping of their assets, clients should review and reconcile any account statements received from CIG with those received from their qualified custodian and should promptly notify CIG and their qualified custodian if any discrepancies are identified. Page 56 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 16: Investment Discretion Overview This section of the Brochure describes our discretionary arrangements when providing investment advisory services to Clients. UBS AMA LLC, including CIG, offers both discretionary (clients who have authorized UBS AMA LLC to execute transactions for their accounts without prior approval) and non -discretionary (clients who require that transactions be either traded by or authorized by them in advance) investment management services. In either circumstance, clients may limit or prohibit CIG from engaging in certain transactions due to asset allocation ranges, restrictions on the purchase of particular classes of securities or specific issuers, or other investment factors or account requirements or guidelines. In addition, clients may further limit our authority by requiring that all or a portion of the client’s transactions be executed through the client’s designated broker -dealer (“client directed brokerage”). Before CIG will assume discretionary authority for a client, the client and CIG must enter into an investment management agreement granting us authority to execute trades for the client. Restrictions and limitations applicable to Fund or Accounts are disclosed within their Governing Documents. Page 57 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 17: Voting Client Securities Overview This section of the Brochure describes how CIG manages proxy votes on behalf of our Clients. Underlying Investments in a Fund or Account may not typically convey traditional voting rights, and the occurrence of corporate governance or other consent or voting matters for this type of investment is substantially less than that encountered in connection with registered equity securities. On occasion, however, an investor may receive a notice associated with an underlying investment seeking the consent of or voting by holders (“proxies”). CIG is required to describe its proxy voting policies and procedures and, upon the request of any client, to provide such person with (i) the actual policies and procedures and (ii) information about votes cast on behalf of such client. These policies and procedures: (i) address CIG’s overall policy to vote client proxies in the best interest of clients. and in a manner that maximizes the value of the client’s investments; (ii) identify the persons responsible for monitoring corporate actions, determining whether and how to vote proxies and submitting proxies and (iii) describe CIG’s approach to addressing material conflicts of interest that may arise in connection with the consideration of a proxy. In general, proxies will be voted in the best interests of its clients, where appropriate, via direction to an independent third party – Institutional Shareholder Services Inc. (“ISS”) which provides issue analysis and conducts voting for proxy proposals. CIG's investment professionals will vote proxies in a manner they believe to be consistent with the best interest of clients. The investment professionals monitor potential conflicts and will take appropriate measures to mitigate any such conflicts. From time to time, conflicts can be expected to arise between the interests of a client, on the one hand, and the interests of CIG and its affiliates, on the other hand. If CIG determines that it has, or may be perceived to have, a conflict of interest when voting a proxy, CIG will address matters involving such conflicts of interest on a case-by- case basis in a fair and equitable manner, seeking to take appropriate measures to mitigate any such conflicts subject to legal, regulatory, contractual or other applicable considerations. Most discretionary clients give CIG the authority to vote proxies on their behalf. However, clients may opt to retain the right to vote proxies for securities in their account. If a client has retained proxy voting rights, the client is responsible for making arrangements to receive proxies and other solicitations directly from its custodian or transfer agents for the issuers. CIG does not generally communicate its proxy recommendations to such clients, but such clients may request to consult CIG with quest ions about a particular proxy. Records of proxy materials and votes are maintained by CIG. A copy of CIG’s full proxy voting policy is available to clients upon request. Additionally, information about how we voted proxies for securities held in a client’s account will be made available to that client upon request. Page 58 of 59  UBS Asset Management (Americas) LLC Credit Investments Group Form ADV Part 2A Item 18: Financial Information Overview This section of the Brochure describes our financial condition, including whether UBS AMA LLC has been the subject of any bankruptcy petition and whether we require fee payment in advance. To the best of our knowledge, there are no financial conditions to disclose at the present time that we believe are reasonably likely to impair our ability to meet our contractual commitments to our clients. Neither CIG nor UBS AMA LLC has ever been the subject of a bankruptcy petition at any time during the past ten years. Page 59 of 59